Check21 is not working for us. We send and receive electronic cash letters, but we're still getting returns after after our holds have dropped off. I've contacted the Fed and they of course will accept no blame. It appears as though the time frame the Fed uses is off compared to the hold times we're allowed to use under Reg CC. Recently, we received a returned check the day that our hold fell off, the customer came in and withdrew everything, and then we received the chargeback later that morning. We've even begun using the cash withdrawal exception in (12 CFR 229.12 (d)). Are there any other banks experiencing this issue?
In light of the check processing districts being centralized we're more concerned now than ever. Currently we use a case by case policy, but is there a different policy that would help protect the bank from fraud?
His judgement cometh....and that right soon.