Total Savings Deposits • Characteristics of Savings Deposits • Institution reserves the right to require 7 days notice prior to a withdrawal • No specified maturity date • Limits on transfers • Limits on withdrawals
Total Savings Deposits • Include as Savings Deposits • Interest/Non-Interest bearing savings deposits • IRA/KEOGH accounts • Club accounts (ie. Christmas Club, Vacation Club, etc) • Escrow accounts • Savings deposits pledged as collateral for loans These accounts MUST meet the definition of a savings deposit to be included!
Total Savings Deposits • Include as Savings Deposits • MMDA, Passbook Savings, Statement Savings that qualify • Include interest credited to accounts
Total Savings Deposits • Savings accounts have a 6 transaction limit • Monitoring systems • Customers who continuously exceed limits should be contacted • Accounts that habitually exceed transaction limits need to be reclassified
Total Savings Deposits • Transaction limits, continued… • No more than 3 of the 6 monthly transactions may be made by: • Check • Debit Card • Phone, Fax, On-line • A general rule of thumb is that convenience counts
Total Savings Deposits • Let’s go through an example • Mr. Smith has a MMDA account at Cleveland Bank • Here is November’s account activity
Total Savings Deposits Date Transaction Qualify Mr. Smith’s checking account at Cleveland bank is overdrawn, so overdraft protection transfers $100 from savings to checking. Yes 11/2/06 Yes Mr. Smith uses his debit card to purchase a new suit 11/5/06 Mr. Smith comes in to the Columbus branch of Cleveland bank and withdraws $150. No 11/10/06 Mr. Smith writes 2 checks off his MMDA account, one for the water bill and the other for his cell phone bill. Yes 11/12/06
Total Savings Deposits Funds are transferred from Mr. Smith’s account to Cleveland bank as part of his monthly student loan payment. 11/15/06 No Yes Mr. Smith uses on-line banking to pay his credit card bill. 11/18/06 No 11/23/06 Mr. Smith goes to an ATM to withdraw $150. 11/26/06 Mr. Smith telephones in a request to withdraw $100 and a cashier’s check is sent to his house. No
Total Savings Deposits • Has Mr. Smith Exceeded the transaction limit? YES! (No more than 3 of 6 made by Check, debit card, on-line)
Total Savings Deposits • Legitimate Differences– Commercial Banks • FR2900>FFIEC 031/041 • Primary obligations • 2900 includes savings deposits of Non-US bank branches, deposits received from non-US affiliates, and balances held by Edge and agreement corporations
Total Savings Deposits • Legitimate Differences- Savings and Loans • FR2900 > OTS 1313 • Primary obligations • FR2900 < OTS 1313 • 2900 excludes certain escrow funds • 2900 excludes balances at Non-US offices of the DI, Call includes them
Total Savings Deposits • Legitimate Differences- Credit Unions • FR2900>NCUA 5300 • Primary obligations • IRA/Keogh balances • Non-member deposits • FR2900<NCUA5300 • Share draft accounts that exceed transaction limits or are not monitored • 2900 excludes balances held at non-US branches of DI, Call includes them
Total Savings Deposits Questions???