With the recent changes in Fed Reserve check processing, many checks that were once considered non-local for us are now local. We need to notify our customers of the improved availability. If we put a short message on our monthly DDA statements that referred customers to our website (or to the nearest office) for the updated Regulation CC disclosure, do you think it would "clear and concise" enough to meet regulatory disclosure requirements? We are a small shop and have always relied on the old postal system to notify customers of changes but now wonder in this day and age, what we can do electonically and still be in compliance.

Does your funds availability policy delay availability on check deposits for a different number of days depending on whether or not the paying bank is a "local" bank? Asked differently, do you routinely hold non-local checks longer than local checks without providing case-by-case hold notices?

If yes, then you have to update your disclosures of how customers can tell if a check is local or not. That's done by listing all those routing numbers -- and if you're in the old Jacksonville area, that list has suddenly expanded tremendously to include all of the Sixth district and part of the Eighth. [By the way, you can avoid listing all those numbers by stating it as four numeric ranges.]

You have to include the disclosure in your notice to consumer depositors. You can't point them to your website to read an important message. But, I'll bet if you condense the list into ranges you can include them in the statement message. Otherwise, consider making it a statement stuffer.

As you know, because this change expands the number of banks that are local to you, your disclosures should be completed within 30 days after the change in check processing regions.

Thanks for the reply John. Yes we do routinely hold non-local checks longer than local and it was spelled out in our disclosure by referencing the first four digits of the 10 that were considered local. Now with 54 that will not work. (I'm not certain I understand what you meant by the four numeric ranges). We had thought to put a notice on our DDA statements like "New availability of funds on check deposits. See our website for details or visit one of our offices." Then...we would have the complete new disclosure on the website. The new disclosure will read "The holding period for other check deposits depends on the routing number on the check. The first four digits, known as the Federal Reserve routing symbol, will indicate the Federal Reserve check processing center of the bank the check is drawn on. For (our bank), a check is considered local if it is payable by or at or through a financial institution located in the Federal Reserve Bank of Atlanta check processing region. Otherwise, the check is a non-local check."
Are you saying we need to be more specific and still display some form of the number? Thanks for you help.

well, this may be more information than you need but the ranges look something like this:

0610 to 0613
0620 to 0622
0640 to 0642
0650 to 0655
0820
0829
0840 to 0843
2610 to 2613
2620 to 2622
2640 to 2642
2650 to 2655
2820
2829
2840 to 2843

regards,
cj

You could even go farther.

0610 - 0655
0820
0829
0840 to 0843
2610 - 2655
2820
2829
2840 to 2843