Regulation CC?Down To The Wire

As September 1, 1990, comes closer, there is still scrambling going on in Washington, D.C. over the final form of Regulation CC.

As the compromises become more clear, it appears that the financial institutions MAY get some small relief from the way the requirements were originally written.

IF Congress passes the compromises before they recess for the summer, we may be able to expect:

(l) Non-proprietary ATM deposits will drop from seven days hold to five. (The same as non-local items.)

The House version says this will be in effect for four years. The Senate says forever?or until they change it again!

This five day hold is still better than the "local items-as if at a teller's window", which is the way it will be if the compromise does not go through.

(2) Exception holds will go from four days to five days on local checks and from four days to six days on non-local.

LOCAL - 2 + 5 = 7

With the final schedule mandating a two day maximum hold on local checks, this means the exception hold on a local check can be two plus five days, or seven days total. If no change is passed by Congress, it will be two plus four-six total.

NON-LOCAL - 5 + 6 = 11

Non-local checks, according to the Expedited Funds Availability Act can be held up to five days on a regular deposit under the final schedule. If you add the allowable five days to the six day exception, your hold on non-local items can be a total of eleven days. If no change by Congress, it will be five plus four-nine total.

There is no change on the possibility of up to a 30 day hold on new accounts, if it is in your disclosure.

Speaking of disclosures - if the changes are passed, it will probably mean all institutions will have to send out new disclosures.

Keep in mind, these changes are not yet official. We'll keep you as up to date as possible.

Copyright © 1990 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 1, No. 6, 7/90