Point 8 is in the commentary and I believe it says a credit card check is not a check under CC.
In the Reg. at (k)(1) it states it must be payable at or through a bank. A credit card check is payable at or through a credit card company or finance company office. The payable at bank is just not the last point of return and it is impossible for the issuing company to follow the timing requirements of CC for returned checks.
I believe we can make the case they do not meet the definition of check in CC. If so, nothing else in CC matters with those items. We can send them forward for collection, refuse to accept them, or accept them with a hold longer than provided by CC.
If they are checks by definition then anything we do could be discriminatory. Eleven days is not enough of a hold for those items.
I'm arguing that banks treat those items like checks (Under CC) when they don't have to. At the least we should be granted greater leeway in handling those items.