A recent internal audit cited our bank held funds on a new acct for longer then allowed. The new acct had a hold for 7days on $5,000 & 11 days on $1,000. and notice ck'd off the exception rule of amt over $5,000... Auditor stated the bank placed the hold not because it was a new acct but because the amount was large. Thus we needed to follow the established acct ck hold time frames.
Questions:
1. Does bank need to complete a check hold notice on a new account or is it not required under the reg as being an exception?
2. If the bank sends a hold notice on a new acct.& the check is over $5,000 what is the proper completion of the form and # of days held?
Thanks

1. No notice is required for holds on new accounts if your new account hold policy is properly disclosed in your initial policy disclosure.

2. Anyway you want to complete it, as long as it is not misleading - see answer to Q #1.