We have decided to review our Reg CC policy (which has not been updated for some time). We are located in 2 states (WV and VA). We previous stated WV local was 0515, 0519, 2515, or 2519 and VA was 0514, or 2510.

I am struggling with what is determined to be a local check according to the Routing Number Guide to Next-Day Availability.

Please help!

You need to determine which check-processing region you are located in. Local checks are checks payable by paying banks that are located in the same check-processing region as your branches are. Once you've determined which region you're in, all of the routing numbers listed in Appendix A of Reg CC (Routing Number Guide to Next-Day Availability Checks and Local Checks) under that region are local.

I'm amazed your examiers haven't cited you for this as Reg CC is an easy one for them to find exceptions with. You need to check Reg CC appendix A. Your bank operated in 2 districes Philadelphia and Cleveland. This for your banks in VA - all of the Routing #'s for Philadelphia are local. For WV -all of Cleveland is local. ( I could have that backwards). You also need to be aware the FRB is constantly consolidating processing centers and by the end of the year or early 2010 there will only be two processing centers one for electonic presentment the other for paper.

Appendix A to Part 229 --Routing Number Guide to Next-Day Availability Checks and Local Checks

We are also reviewing our funds availability brochure and find ourselves in the same postion as the person that posted this thread in that we haven't listed all routing numbers as local that appear for our Fed Districts in the Appendix. Does it make a difference if we list a number of routing numbers in our Fed District under the non-local category since we provide second day availability for non-local checks (well within the 5 day max allowed)?

If your customers don't need to know if a check is local or non local to figure out when normal availability will occur, you don't need the routing number list. If you treat local and non local checks the same, that's the case. But if you give next day availability on local checks and 2nd day on non-local, you need the list.

I have a follow-up question. We are located currently in the Minneapolis District (soon to be in the Cleveland district). We have an unusally high number of routing numbers in this district that are considered "country" items - where paper actually needs to be delivered. The Fed provides two day availability on these items to us. We provide next day availability to our customers on our local items. Is it okay to not include these items as local in our routing number list?

Not if those banks' routing numbers are (or will be) included under the Cleveland office in Appendix A to Regulation CC. The local/non-local designation is absolute based on the check processing region of the branch that accepts a check for deposit and the bank represented by the routing number on the check. It doesn't change based on whether paper has to travel or not.