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#702169 - 03/16/07 02:39 AM Funds Availability Policy Notice
Paris Offline
100 Club
Joined: Dec 2005
Posts: 173
Honolulu HI
I'm asking these questions because our internal auditors are asking these questions.

Shouldn't we have a Funds Availability Notice posted at the Drop Box??

Are we required to post a notice at the Drop Box where customers can drop their deposits during the day? The drop box is in the teller lobby and we have the funds availability notice posted at two locations throughout the teller line.

Also...if the new account representatives accept deposits are they required to have the funds availability notice posted on their desk?

I don't see why this would be necessary. They provide the funds availability notice to the customer before opening the account and accepting the deposit.

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Deposits and Payments
#702180 - 03/16/07 11:49 AM Re: Funds Availability Policy Notice Paris
Wore Out Offline
Platinum Poster
Wore Out
Joined: Dec 2003
Posts: 543
Kentucky
Below is the excerpt from the official commentary:

B. 229.18(b) Locations Where Employees Accept Consumer Deposits

1. This paragraph describes the statutory requirement that a bank post in each location where its employees accept consumer deposits a notice of its availability policy pertaining to consumer accounts. The notice that is required must specifically state the availability periods for the various deposits that may be made to consumer accounts. The notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits. For example, the notice might be posted at the point where the line forms for teller service in the lobby. The notice is not required at any drive-through teller windows nor is it required at night depository locations, or at locations where consumer deposits are not accepted. A bank that acts as a contractual branch at a particular location must include the availability policy that applies to its own customers but need not include the policy that applies to the customers of the bank for which it is acting as a contractual branch.
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Not even close to being legal advice....I have a bridge for sale too!

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