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March 02, 2012

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Joyce

I just got back to the office and of course, this blog is the 1st place I go to for a quick catch-up of what I missed while out. These are excellent blogs, Steve! And so on-point. It certainly does seem as tho the CFPB forgot all about Reg D's limitations but I also have to wonder that with today's technology there must be some other way that we can determine reserve funds. The 6 limit is certainly outdated but the regulators need to look beyond just this number of 6...they need to improve the way the reserve requirement is determined. I'm sure they won't have to look far to come up with a better method and this part of the OD mess will be solved.

Steve Van Beek

Joyce,
As always - very good points. With the ability to transfer funds via a smartphone from anywhere on the world, the existing Reg D setup does look a bit outdated.

Thanks again.

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