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?
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
Is there any where in Reg CC that states the bank can hold a check for the entire amount for a New Account?
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?
Our front line staff creates the hold notice and then sends to the Fraud Dept to review and put on the system.
Often times the front line does the Hold Notice Wrong. If we change the Hold Notice we send the customer a new one. If we decide the hold is not necessary are we required to send notification to the customer informing them their funds are available sooner then we originally informed them?
What is your view on retention of the physical deposit hold notices to meet Reg CC retention requirements? We recently converted our core system and have the opportunity to electronically record data used to populate deposit hold notices rather than retaining the physical forms.The data will be in the form of a report rather than a customer view of the notice. Parameters are set in the system for hold types, hold days, and makes consideration for multiple hold scenarios such as large deposit hold for amount over $5,000, two day availability for $4,800, and next day for $200.There is also a required field for facts to support reasonable cause holds when confidential information is selected.
Could you give me your thoughts? Most believe Remote Deposit of check images are subject to Reg CC mandates. I have observed on BOL that this is not the rule, but is a best practice?
Does Regulation CC apply to savings accounts?
Has there been any update to the status of Regulation CC? We are getting ready to reprint disclosures, and wonder whether we should place our usual order or cut back to anticipate change.