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#1114962 - 01/22/09 03:28 PM Reg CC vs Check21
IronWill Offline
New Poster
Joined: Nov 2006
Posts: 11
Florida
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?

Please help.
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#1114970 - 01/22/09 03:34 PM Re: Reg CC vs Check21 IronWill
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You could utilize exception holds.
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#1116412 - 01/23/09 08:49 PM Re: Reg CC vs Check21 BrendaC
IronWill Offline
New Poster
Joined: Nov 2006
Posts: 11
Florida
We use exception holds where possible. Unfortunately, it's not always possible. For the case by case holds, there just seems to be a small window where the hold falls off but we havn't received the returned check and some of customers take advantage of it.
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