We are contemplating making it standard procedure to always place a hold on new accounts. Currently, the Bank has a normal availability policy. Can we place holds on all new accounts and continue to have a normal availability policy?

Define a "normal availability policy." Do you mean that you grant next-day availability for all deposited checks? Or do you mean that you automatically apply the statutory holds to deposited items?

Either way, you can implement an extended hold for new accounts. It will be necessary for you to amend your funds availability to reflect the change in your practices. Normally, you would be required to give your deposit customers 30 days notice of the change. But since any customers affected wuld not be new customers by the time the change took effect, I think you could simply implement the change for new accounts as of a particular date.

The standard hold for new accounts seems to be nine business days.

Yes, I do mean that we give next day availability for all deposits. I take it that we still would have to disclose this new procedure to our customers in our Funds Availability Disclosure.

Yes. See 229.16(b)(3). The timing of you notice of change is governed by 229.18(e).