For new accounts:
Commentary to Reg CC (229.13(a))states that the schedules for local and non local checks do not apply, and, unlike other exceptions provided in this section, the regulation provides no maximum time frames within which the proceeds of these deposits must be made available for withdrawal.
There is reference to reasonable time in the reg but only with respect to exceptions other than new account exceptions.
So, can we then hold these funds for 14 days for instance?
Our disclosure says nine days, but if we change that, then we can hold these funds even longer, according to what I'm reading.
How long do others hold funds for new accounts?
I'm asking because this is where fraudulent activity is mostly occuring (stolen checks, forged checks, etc.).
Lastly, if we're not required to give notice at the time of extending the hold for a new account, what are we required to have on the initial disclosure? The reg says to disclose the time funds generally will be available.
Would a statement such as 9 to 14 days be sufficient?
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