When will the 2011 version of the Reg CC date availability calendar be available?
What is the $5K next day rule for funds availablity?
We’ve gotten some confusing information regarding funds availability recently, and I want to clarify. It was always our interpretation that if a deposit is made today, a two day hold is placed that would expire during account update on the second day, and that any pending transactions on that day would be processed. It has recently come up that the funds should be made available by the second day, meaning as of the time of opening for business. Can you elaborate your interpretation of this Reg and how funds are to be made available?
In Reg CC, 229.13(g)(5), it states that we have to retain notices for exception holds along with a brief description of the reasoning for the exception hold. Does the regulation talk about a copy of the actual delayed funds availability notice that was sent to the customer, or would a software system that stores the vital information from the notice be sufficient? After reading Appendix E to 229.21 (g)Commentary to record retention, it sounds to me that a copy of the actual notice provided to the customer must be retained.
Under Reg CC holds/guidelines, is a bank required to follow the $100 next day availability guidelines or can we give more than the $100?
When using the large deposit exception hold provision of Reg CC, when does the first $5,000 of the deposited checks have to be released?
Where is it stated that Reg CC does not apply to foreign checks? Example: checks drawn on a Canadian bank should be sent for collection and that a Reg CC hold does not apply in this situation. I can not seem to find this in any material.
When did Reg CC require Funds Availability signs at all locations that take deposits, and does an address now have to be displayed on the HMDA compliance sign? I heard that it needs to have an address at each branch, but not in the main office. What is correct and when did the change go into effect?
I have always heard that if a loan is not new, i.e., if the transaction pertains to increasing, extending, renewing, or purchasing an existing loan, the determination can be reused if it was intially recorded on a SFHDF, it is less than seven years old, and the info is still current(no map changes have occurred). However,I was recently told that a new determination would be required if the customer accepted a "skip-a-pay" offer or deferred a payment, because this would change the term of the loan. Is this correct? This seems contradict what I was previously told.
We received a check from an attorney to put into an escrow account for our customer. They can receive draws on the check, but only as the work is completed. Can we put a hold on these funds and be in compliance? What suggestions do you have?