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#1126831 - 02/10/09 04:41 PM Reg CC Lobby Notice
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
I have a question regarding our Reg CC lobby notice. Our Reg CC policy states that for case by case hold our general policy is fund will be avaiable no later than 5th business day. Our exception hold is that funds will generally be available no later than 7th business day. My question is for our lobby notice which day do we disclose 5th or 7th?

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#1126855 - 02/10/09 04:51 PM Re: Reg CC Lobby Notice ahkcompliance
ahanna Offline
Gold Star
Joined: Aug 2008
Posts: 380
Texas
You will use the 5th day on your lobby notice. See the below model form taken directly from the Reg:


C-18--Notice at locations where employees accept consumer deposits
(case-by-case holds)

FUNDS AVAILABILITY POLICY

Our general policy is to allow you to withdraw funds deposited in your account on the (number) business day after the day we receive your deposit. Funds from electronic direct deposits will be available on the day we receive the deposit. In some cases, we may delay your ability to withdraw funds beyond the (number) business day. Then, the funds will generally be available by the fifth business day after the day of deposit.
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In the end, it's all just a bunch of paper....

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#1126861 - 02/10/09 04:54 PM Re: Reg CC Lobby Notice ahanna
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
but it could be 7 business days? Don't we want to disclose worst case?

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#1126906 - 02/10/09 05:11 PM Re: Reg CC Lobby Notice ahkcompliance
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
The "general" rules cover case-by-case holds, not exception holds. Go with model language.
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Life without Jesus is like an unsharpened pencil - it has no point.

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