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?

I'm a little confused by your question, as Reg CC, under new accounts seems real clear:
(ii) Is subject to the requirements of Sec. 229.10(c)(1) (i) through (v) and Sec. 229.10(c)(2) only with respect to the first $5,000 of funds deposited on any one banking day; but the amount of the deposit in excess of $5,000 shall be available for withdrawal not later than the ninth business day following the banking day on which funds are deposited;

So, nine days is the max.

I would note that they would be available for withdrawal by the beginning of the 14th business day after deposit. (You will need to be able to justify that 14 days is reasonable.)

Remember that the exception that does not limit the time requirement only applies to local and nonlocal checks. Certain other checks and cash deposits have maximum hold requirements even for new accounts.

Thank you for the input.

I should have been more specific. I was asking my question with regards to local and nonlocal checks. Kansayaku hit on that. The way I understand it, section 229.10(c) refers to certain check deposits, ie. Treasury, U.S. Postal, etc.

At this point, I’m more concerned about the local and nonlocal checks and how long we can reasonably hold them on new accounts.

Since we recently took a hit because of fraudulent activity, I just wanted to get a feel for how long others have held funds on new accounts and if we should think about changing our disclosure and going longer than nine days to better protect ourselves.

We disclose that all other checks (local and non-local) will be available on the 5th business day after the date of deposit.

I guess we aren't very worried about it here.

What is the timeframe for the returns for stolen/forged items? Would increasing your new account hold to 14 days have stopped the losses? This info should be your documentation to justify increasing your new account hold times.

9 days is our maximum new account hold time, but as far as I know we have not had any new account losses.