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Reg CC Hold on Deposit of Cash & Local Check
Jim Bedsole, BOL Guru
Guru Bios
Question: If a deposit is made using $2,000 in cash and $9,000 local check what are my hold options through Reg CC?
Answer: Assuming the deposit is made in person to an account held by the payee of the check and the account is not considered a new account under Reg CC, the $2,000 cash must be made available next business day. For the $9,000 local check, the first $100 would need to be made available next business day. $4,900 could be held until the second business day and the remaining $4,000 held until the seventh business day under the large deposit exception hold.
However, the equation changes if any other exception reasons can be applied (redeposited item, repeat overdrafts, reasonable cause to doubt collectibility, or emergency conditions). If any of those apply, the entire $9,000 could be held until the seventh business day.
Finally, if the account is a new account under Reg CC, then the entire $9,000 could be held until whatever timeframe is specified for new accounts in your Funds Availability Policy.
First published on BankersOnline.com 1/23/06
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