We send image cash letters to the Fed, and only route NCI's and other non-imageable items via paper.

Since the image CL's are still being routed the same way, is there an impact on how we handle holds when the FRB makes changes to their processing centers?

I see that BOL is having a session on Reg CC soon and I hope to attend, but this question was posed today by our IT area and I don't think I can wait to provide the answer.

Thanks, in advance!

...I found the information I was looking for...

OK ... so, section 229.18 of Reg CC reads:

(e) Changes in policy. A bank shall send a notice to holders of consumer accounts at least 30 days before implementing a change to the bank's availability policy regarding such accounts, except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation.

So because this change is going to expedite availability, we can disclose it within 30 days after the change (we're in district 9 so we have a change coming soon), correct?

Are most of you just using a statement message indicating that more checks are considered local, or using some other method?

(Pardon my ignorance...I picked a bad time to transition in to compliance with all these changes at once!)

Yes - you can disclose within 30 days after the change.

We added a note on our account statements and listed the first four of the R/T #s that are considered local for our region (Atlanta).

JMunns -
Did you list *all* of the RT's for you region, or just those that were recently added?

It was difficult, but we listed all that were considered local. I do know that a colleage at another institution only listed the recently added, i.e.
"Checks beginning with Routhing #XXXX, XXXX, are now considered local checks in our funds availability policy."

I will also warn you to review your Reg CC disclosure provided to customers at account opening. We thought we updated everything and our internal auditor found that our initial disclosure listed the specific routing numbers and therefore we were out of compliance. Needless to say we changed the disclosure so that the R/T's are not listed and won't have to be updated each time the Fed consolidates check processing centers.

Thank you for your help!