Latest Compliance - Reg. CC Topics

10 Day Hold on Check?’

09/19/2021

I am wondering if it is against regulations to place a 10-day hold on a check? I always thought we couldn't go past 9 days. Please refresh my memory!

Making Reg CC holds easier

08/29/2021

Can a bank that generally makes check deposits available the day after the deposit decide not to make case-by-case holds but employ exception holds when needed?

Making Reg CC hold amounts easier

08/22/2021

The inflation-adjusted dollar amounts, especially $225 and $5,525, in Regulation CC are cumbersome to work with. Can a bank “round them up” to amounts that are easier to work with, such as $250 and $5,600?

Reg CC Guidelines for a Timely Notice

08/15/2021

Under Reg CC, I need assistance in regards to when a notice must be mailed to a customer for an ATM deposit. To detect and prevent fraud losses, our detection teams currently review ATM deposits made to an account on the same day of deposit, but prior to posting to a customer's account or prior to our processing area posting it to a customer's account. After nightly posting by our core system, when transactions are posted and services are updated for the next day's work, holds are then applied to the account (early AM time, Day 2). Reg CC notices are mailed the following day after the hold is applied. Does this fall within the Reg CC guidelines for a timely notice or since we reviewed the deposits (prior to posting) do we have to send a notice the following day, basically the same day the hold is applied to the account?

Retention for Hold Notice/Funds Availability Form

07/11/2021

Can anyone tell me what the retention period is for hold notices/funds availability forms? I have checked with our state bank department and this form was not specifically addressed. If it is not uniformly required, how long do other banks keep these Reg CC notices, and what about cash advance receipts (Visa)?

Notice of Delayed Availability

01/24/2021

Is a Notice of Delayed Availability form required to be mailed to customers who deposit local checks in excess of $5,525 or is it only required if a statutory exception hold is invoked or a case-by-case hold is placed? In other words, if a local check deposit of $6,000 was done at the ATM and the funds are being held $225 (first day) $5,300 (second day) $475 (7 days) would the customer need to be mailed a form?

Availability for Large Check Split b/w Accounts

01/17/2021

If a large not-on-us check was split between a new savings account and an existing checking account, (not the ideal scenario) would you split the availability of the $5,525.00 on the 2nd business day between the two accounts and make the balance available on the 9th business day?

Can You Place a Reg CC Hold on a Savings Bond?

01/10/2021

Can you place a Reg CC hold on a Savings Bond?

Reference Acct # on Hold Notice Reg CC

11/22/2020

I just finished taking a Reg CC training through ICBA, and it mentioned that we should have a maximum of 4 characters to reference the account number on a hold notice. I can't find this verbiage on any other Reg CC training I have done recently to this. Is this the requirement?

State University Check: Government Check/Reg CC?

10/11/2020

I would like to know if a check issued by a state university in the same state of our bank is considered a government check for Reg CC purposes?