Question & Answer
Question: We occasionally place exception holds for large deposits. Some of our tellers are inconsistent in making funds available. For example, some always make the first $5,000 available and others make $100 available. What is correct?
Answer: The large deposit exception hold may only be placed on the amount of a deposit that exceeds $5000. This special exception hold permits you to aggregate all checks in the deposit and place a hold on the amount that exceeds $5000. The first $5000 of the deposit must be made available on the appropriate availability schedule for local or non-local checks.
The period of the large deposit hold must be reasonable and is not affected by whether the check is local or non-local. Also, remember that you may not use this hold for electronic transfers. If your bank's policy is to make funds available before the time required by the regulation - such as immediate or next day availability - you may place a case by case hold on the deposit for the full period allowed by the regulation.
Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 15, 10/96
First published on 10/01/1996