Our Reg CC Policy that is given out initially (and of course is located in our lobby!) states for new customers that "we reserve the right to apply the following special rules during the first 30 days your account is open " and goes on to talk about holds and certain check deposits that would be available on the 9th business day after the day of the deposit. My question is...do we need to provide a hold notice to a new customer at the time of the deposit if we decide to place a hold on their deposit? or is the initial hold disclosure sufficient? I am leaning towards having to give the customer a hold notice at the time of the deposit.

You do not have to give a hold notice for new account holds; you do have to provide one for all other hold reasons.

Thank you! I reviewed REG CC again and found the answer in Sec. 229.13 Exceptions. You are correct.