Reg CC-I hope you can please clarify the requirements under Reg CC once and for all. When we receive notification of a large item return, our understanding is that our only obligation under Reg CC, is section 229.33 (d) notification to the customer. At that point, we may put a hold on the funds until we receive the check back from the paying bank, but that subsequent hold does not fall under the Reg CC Funds Availability hold rules since Reg CC Funds Availability hold rules only deal with funds that are deposited at the time of initial deposit, rather than subsequent efforts to collect a return check. Otherwise, how would that hold be filled out when the funds are not being deposited, the funds are never going to be made available, etc.
How long can you place a Hold on a Large Check Deposit made to a Savings account?
Are saving accounts governed under Reg CC?
I would like to know more about Expedited Funds Availability Act.
We don't place the regulatory 9 day hold on new account deposits. However, we do place exception holds once in awhile (7 day). A Compliance Trainer told us that if you do the regulatory 9 day hold on new account deposits, you have to do it for all of them - you can't pick and choose. Is that true?
We have a case-by-case hold policy at the bank where I work. We give a written hold notice to customers when we are placing a hold on their deposits. We have one customer who makes multiple deposits each week. Due to the history on the account, we place a hold on all check deposits into this account. The customer is aware of this. Are we permitted to forgo the written notice step of the case-by-case hold for this customer?
I understand that Reg CC availability schedules do not govern checks deposited to nontransactional accounts. However, I have also read that if you give your Funds Availability policy to all account holders regardless of the type of account, as many banks do to avoid the possibility of failing to give it in required situations, that your actual availability policy for nontransaction accounts must match what your disclosure says. Should the bank add a clause to the disclosure or can we qualify the reference within the disclosure to read "funds deposit into your 'transactional' account may be delayed...."
If a customer deposits a cashier's check for $50,000 and the branch wanted to place a case by case hold, should the first $5000 still be made available and the remaining $45,000 held for two business days?
According to Reg CC, does the bank have the right to delay availability for withdrawal of cash or similar means by one business day, and only provided $400 deposited fund available for cash withdrawal?
I am an Internal Auditor and would like to know if the Notice of Availability is disclosed on a deposit envelope at the ATM, does that satisfy the sign display requirements?