Thread Options
|
#120415 - 10/06/03 05:02 PM
reg CC question
|
Anonymous
Unregistered
|
if you deposit $10,000 check and $2,000 check in one single deposit. YOu put a hold on the $10,000 check, do you have to make the $100 available since you haven't put a hold on the $2,000 check(which will be available next day)? Will the scenario be different if the customer got some cash back with the deposit? Thanks for your help.
|
Return to Top
|
|
|
|
#120416 - 10/06/03 05:20 PM
Re: reg CC question
|
10K Club
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
|
I'm not a Reg CC expert and don't deal with it on a daily basis, but if I understand it correctly, under Reg. CC you are not putting a hold on individual checks (unless the deposit is only 1 check), you are putting a hold on the total deposit. Therefore you would be able to place your normal hold requirements and only the $100 would have to be made available, and if they took back cash you have made the $100 available (providing the cash back was at least $100).
I'm basing this opinion on 229.10(c)(vii)(b) where it refers to the "aggregate" amount deposited by check or checks.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.
|
Return to Top
|
|
|
|
#120417 - 10/06/03 05:22 PM
Re: reg CC question
|
10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
|
You didn't say what type of checks were deposited, i.e., next-day, local, non-local, as it will make a difference. Do you want to take advantage of the large item exception? Making funds available the next-day or giving cash back will get you to the same place.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#120418 - 10/06/03 06:22 PM
Re: reg CC question
|
Anonymous
Unregistered
|
Thanks for the info. Do we still have to make $100 available, if the customer did not receive any cash back? Does it make a difference that you only hold one check, for $100 purposes...
|
Return to Top
|
|
|
|
#120420 - 10/06/03 06:41 PM
Re: reg CC question
|
Anonymous
Unregistered
|
Ok, the 2,000 check is not a next day item, but we make all funds available the next day, unless there is a hold. As mentioned above, reg CC applies to the total deposit if you have more than one check... But what if 2 checks deposited but you only want to place a hold on one of them. So the other item is available the next day.. This is where I am struggling. We already make the funds on the other check available the next day..... do we still have to give another $100?
|
Return to Top
|
|
|
|
#120421 - 10/06/03 06:45 PM
Re: reg CC question
|
10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
|
Look to the aggregate amount of the day's deposits. Since you already made $2,000 available from a local or non-local check, you have no obligation to make any additional funds from other local or non-local checks deposited during that business day - whether they make one deposit or multiple deposits and whether those consist of one other local or non-local check or a thousand of them.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#120422 - 10/06/03 06:57 PM
Re: reg CC question
|
Anonymous
Unregistered
|
I feel like I am going around the circle...I am very sorry since this is a very confusing topic for me. how do you place a hold on multiple deposits. customer deposits $12,000 in aggregate, but you want to place a hold on $10,000 check. Doesn't that contradict the concept of placing holds on the total deposit? Do you fill out a hold notice for $10,000 amount?
|
Return to Top
|
|
|
|
#120424 - 10/17/03 07:21 AM
Re: reg CC question
|
Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
|
If you are placing a "Case-by-Case" hold and neither of the checks were a "Next-Day" item, then your hold would be like this:
TOTAL DEPOSIT - $12,000
AMOUNT AVAILABLE NEXT BUSINESS DAY - $2,000
AMOUNT AVAILABLE IN (2 or 5) BUSINESS DAYS - $10,000
2 days if the item is local
5 days if the item is non-local
If you are placing a Large Deposit hold, and neither of the checks were a "Next-Day" item, then your hold would be like this:
TOTAL DEPOSIT - $12,000
AMOUNT AVAILABLE THE NEXT BUSINESS DAY - $2,000
AMOUNT AVAILABLE IN (2 or 5 ) BUSINESS DAYS - $3,000
AMOUNT AVAILABLE IN (7 or 11) BUSINESS DAYS - $7,000
2 days and 7 days if the item is local
5 days and 11 days if the item is non-local
_________________________
CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
|
Return to Top
|
|
|
|
|
|