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Excuse Me-What Was That Again?

"Excuse Me-What Was That Again?"

Once upon a time there was a banker who was having problems with the examiner who was in his institution.

It seems that his disclosure stated that there would be a twelve day hold on all local or non-local checks deposited into a new account. The examiner said that it was not permitted to put that long a hold on those deposits, stating that only a nine day hold was allowed.

The banker remembered attending one of my Regulation CC seminars where I emphasized that you could put up to a 30 day hold on local or non-local checks in a new account, as long as you had the facts in the disclosure. He asked if I could document my statement.

I had no trouble doing that. I pulled out my Regulation CC, copied section 229.13, and was ready to send it to him. Then, to be sure there was not a recent change of which I was not aware, I called the regulatory office in Washington, D.C.

What an interesting exercise! The conversation went like this:

"Good morning! I'd like some information on new accounts and Regulation CC."

"Certainly. How may we help you?"

"How long a hold can you put on local and non-local checks deposited into a new account-that is an account less than 30 days old for a brand new customer?"

"Nine days." L o n g silence?

I said, "Are you sure? Did it change from the 30 days originally written into the law and the regulation?"

"Let me check." L o n g wait?

"Barbara, you're right. It is up to 30 days. We've been giving out some incorrect information, I'm afraid. Its been awhile since we've worked with this and you tend to forget."

Moral of this story: "To be forewarned is to be forearmed."

Copyright © 1990 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 1, No. 3, 3/90

First published on 03/01/1990

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