When it comes to holds - A customer has account A (that has a history of NSF checks, and account B (that has not had a history of NSF activity). Can we put an exception hold on a check in account B due to the activity in account A?

Thank you for the help - inquirying minds want to know

bump - are there any hold experts out there?

Good question... not sure of the answer, but I think I would take my chances and apply a global approach to the customer's relationships... as long as they are both personal accounts, I might just try to do so.

I wouldn't consider myself an expert, but I think the answer is yes.

12 CFR §229.13(d) Repeated overdrafts. If any account or combination of accounts of a depositary bank's customer has been repeatedly overdrawn, then for a period of six months after the last such overdraft, 229.10(c) and 229.12 do not apply to any of the accounts.

now digging into this a little more I see that the customer's other account was charged off more than a year ago. reading through the commentary for repeat overdrafts, it doesn't seem as though this situation would allow for a hold? I'm confused I guess.

If Account A was closed over a year ago, its history can't be used to justify a hold on Account B, since the exception requires overdraft activity within the last six months.

But if both accounts are open, and Account A has sufficient ODs to trigger the exception, holds could be placed against Account B if owned by the same customer.

OKay another twist, the funds being deposited were from another bank, drawn on an account owned by a person who repeatedly writes bad checks to various people with deposit accounts at our bank (and other banks I'm sure). Could we have used a "reason to doubt collectablity" exception?

Assuming you can document your assertion, not just state it as fact, the fact that the item being deposited is drawn on an account with frequent OD activity gives you "confidential information" that would cause you to believe the check may be uncollectible.

Note that you are trying to protect your bank from your own customer, one who has a prior charge off. The least time consuming way to do that is to close the account.