If we have staggered cutoff times among our branches (some at 3:00, some 5:00 or later), do we have to disclose under Reg. CC the practice for that particular branch, or the cutoff time for the bank as a "whole"? How about calculating hold days? Does this raise any other regulatory issues (I can't think of any)?

If I were a customer, I would want a list so I can figure out if I can make it to a later branch if I need credit today.

Al

Great idea! What do you think about the issue of having one Funds Availability policy for the whole bank, though?

Sure. The policy says that funds are generally available the next business day (if true) "if the deposit is received before the cut-off hour [see chart below for individual branch cut-off hours]. If received after the cut-off hour the deposit is considered received the next business day."

Then only the chart needs to be revised if the cut-off hour changes.

Al