Question: One of our customers recently deposited a check drawn in Canadian dollars. The check was drawn on a bank in the United States. The customer explained to us that it is payment for work performed in Canada and that is why it is drawn in Canadian dollars instead of US dollars. What kind of hold can we place on this check?
Answer: You may place any kind of hold you want. This check is not subject to Regulation CC hold limits because it is not drawn in US dollars. For authority on this, see 12 CFR 229.2(k), Regulation CC's definition of check. It specifically excludes any non-cash instrument that is not drawn in US dollars. The check your customer deposited is therefore not a "check" within the meaning of Regulation CC even though it has all the attributes of a check or negotiable instrument and even though it is drawn on a US institution.
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