ACH Deposit Holds
Answer by John Burnett, BOL Guru Guru Bio
Question: Can we place a hold on an ACH deposit?
Answer: If the deposit is one received by your bank as the RDFI for your customer as the receiver, the transaction satisfies the definition for an electronic payment to the account, and your customer must be given at minimum next-day availability of the funds. Under the NACHA rules and Treasury Department rules (if the deposit is a benefit payment from Treasury), you are likely to be required to provide availability of the deposit on the day you receive final credit and the information to post the transaction.
If, however, the ACH deposit is actually credit you are giving your depositor for a transfer being initiated via the automated clearing house from the customer's account at another financial institution (your bank is initiating a debit entry to the other bank's account on your customer's behalf), the entry to your customer's account isn't a deposit subject to Regulation CC, because it neither fits the definition of electronic payment nor qualifies as a check deposit. Instead, it's an internal credit to the account, and it's customary for many banks to deny access to those funds for at least two business days, in order to allow time for the debit entry to reach the RDFI and be returned to your bank as the ODFI, if there is a problem. In such a case, yes, you may place a hold.
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