Latest Compliance - Reg. CC Topics

Reg CC-Minimum for Large Dollar Return Notice

04/07/2019

Has the minimum for a large dollar return notice been raised from $2,500 to $5,000?

Reg CC Multiple Low Risk Items-$5,000 Rule

12/16/2018

Per Reg CC, when multiple low-risk items are deposited within the same deposit, would the first $5,000 rule apply to each low-risk item, or would just the first $5,000 of the total deposit need to be made available?

Cashier Checks Deposited Together as Large Deposit

11/11/2018

When two cashier's checks are deposited together and held as a Large Deposit, should $5,000 of the total be made available immediately or is $5,000 from each check ($10,000 of the total deposit) made available immediately?

How to Handle Scams Involving Fraudulent Checks

07/15/2018

My question has to do with scams involving fraudulent checks and how we should handle the check when a customer presents it for payment. Specifically, we had a customer bring in a check for $2,900 that just didn't feel right for the type of business the customer normally conducts. The teller inquired about the check. The customer explained that he had enrolled online as a secret shopper. He was to keep $300 for himself and spend the other $2,600 buying specific merchandise to send back to the company that sent him the check. The teller called the bank on which the check was drawn and was told that it was fraudulent. We have had a law enforcement official tell us that we need to deposit the check anyway, put a hold on the account so that the funds are secured, and wait for the check to be returned so that we have a paper trail and proof that the check is fraudulent. In addition, once we have proof that the check is fraudulent, we should give the returned check back to the customer so that they can file a complaint with law enforcement. Is this the proper way to handle the check?

"Unable to Verify Funds" Reason to Place Hold?

06/24/2018

I need an updated answer for 2016! Please re-enforce that "unable to verify funds" is not a valid Reg. CC reason to place a hold on funds.

New Reg CC Rules-Differentiate b/w ECI & RCC

05/13/2018

With the new Reg CC rules effective July 2018, how will a user be able to differentiate between an electronically created item (ECI) and a remotely created check (RCC)? Will there be an indicator on the file that identifies these items?

Availability Date: Reg CC Notice for Charge-Backs

08/20/2017

Is a funds availability date required when using the Reg CC hold notice for large dollar charge-backs? The regulation requires you to state on the notice when the funds will be available, however, when you know the item will be charged back then are you not incorrectly informing the customer?

Reg CC Hold Check for Entire Amount for New Acct?

05/28/2017

Is there any where in Reg CC that states the bank can hold a check for the entire amount for a New Account?

Reg CC Extend 7 Day Hold on Fraudulent Check

05/07/2017

We have a check that we believe is fraud. We put a 7 day hold on the check and it is now the 7th day. We verified the check is fraudulent but has cleared the account. The issuing bank has not yet responded to us about this as they don't seem to worried about it. Is there a way to extend the hold?

Are Online Bill Payment Checks Subject to Reg CC?

04/16/2017

Are Online Bill Payment checks subject to Reg CC?