The model branch disclosure for case by case holds does not reference a cut-off time. If your cut off time is the close of business, and you are not open on the weekend, do you need to post a cut-off time? Also, if you are using remote capture, and the last posting time for those deposits is after the close of business but before the next day, how do you disclose this?

C--18--Notice at Locations Where Employees Accept Consumer
Deposits (Case-by-Case Holds) (permanent schedule)

FUNDS AVAILABILITY POLICY

Our general policy is to allow you to withdraw funds deposited in your account on the (number) business day after the day we receive your deposit. Funds from electronic direct deposits will be available on the day we receive the deposit. In some cases, we may delay your ability to withdraw funds beyond the (number) business day. Then, the funds will generally be available by the fifth business day after the day of deposit.

If you have this Policy posted, then I would suggest you provide a hold notice to your affected customers as well. Then you will be 100% in compliance.

bump