CUNA writes Fed to lift cap on Reg D savings account transfer limit

WASHINGTON, DC (May 13, 2019) — The Credit Union National Association (CUNA) today wrote the Board of Governors of the Federal Reserve System to share concerns regarding the Board’s current limit of six transfers per month from a savings account, as outlined in Regulation D. “We believe such threshold is arbitrary, antiquated, and unnecessary,” the letter reads. “At the very minimum, the Board should increase the transfer limit to at least 25 transactions per month… [W]e believe it is long overdue for the Board to update this limit that has its roots in the early 1980s.”

CUNA maintains that the current limit under Regulation D limits consumers’ control over their funds, and places them at risk for diminished overdraft protection should an overdrafted checking account attempt to pull funds from a savings account that has met its monthly limit on transfers.

Section 204.2(d) of the Board’s Regulation D (Reserve Requirements of Depository Institutions) establishes a limit of six transfers per month from a consumer’s savings or money market account when made by various “convenient” methods, such as an electronic or online transfer. Under the current framework, after the sixth withdrawal or transfer, consumers may only access their funds through an ATM or an in-person visit to their financial institution. 

Today’s letter was in response to an advance letter of proposed rulemaking.

About CUNA

Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 135 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit


CUNA Communications


More News