We are a small hometown financial institution. Our funds availability policy is to give immediate credit for all deposits. On occasion, we issue a hold notice. With the upcoming Reg CC changes, there will no longer be a non-local check. Will our current disclosures change? If so, will we need to give advance notice, and what will that notice entail? Also, will a hold ever be placed again? Lastly, even though FRB check processing regions have been consolidated already, the new regulation does not take effect until February 27, 2010, correct?
Should a bank ever go by a customer's "collected balance" when deciding to pay a check for a non-customer or to purchase a cashier's check? I was always taught not to go by that balance but to go by "available" because "collected" has to do with the different routing numbers on checks deposited. If you do not put a Reg CC hold on a check, isn't it against the regulation to not pay against that check even though you did not put a hold on the check and notify the customer of the hold? This has been the big discussion at our bank and this is the first bank I've worked at that even goes by this balance.
Under Reg CC does the Bank have to disclose routing numbers for local or non-local checks? We disclose the Funds Availability disclosure. Are the routing numbers disclosed just for convenience to the customer?