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Question: A banker in New Jersey asks: "We had a three day hold on all deposits made at non-proprietary ATMs until September 1, 1990, when we went to two days, as the law instructed. We notified all our demand deposit account holders of the change with a new disclosure sent through the mail.

"After the amendment was passed allowing us to put a five day hold on those deposits, we decided to change our policy to the five day hold.

"Do we have to send out a new disclosure to all of our demand deposit account holders again, or can we just send it out to those who hold ATM cards?"

Answer: You sent us to the experts again. We contacted two officials at the Federal Reserve Bank. Both gave us the same response.

Regulation CC was not intended to put an undue burden on the financial institution. Therefore, in the opinion of both officials, notification of those customers who already have ATM cards, and therefore have access to the service, is sufficient IF, AT THE SAME TIME, your other disclosure stock is changed. That means that new account customers, or those who apply for an ATM card after the change, will be given availability disclosures with the new information. The new disclosure will also, of course, be available on request.

Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 1, 1/91

First published on 01/01/1991

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