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#1223042 - 07/27/09 09:12 PM what am I missing? Reg CC question
ckb Offline
Member
Joined: Apr 2009
Posts: 80
We place case-by-case holds at my institution.

I know most of the Reg CC Tools show that for NEW accounts, on non-next-day itmes, we can place an 11 day hold. Can someone point out where I can find that?

All I can find in the reg is a 9 day hold:

(ii) Is subject to the requirements of 229.10(c)(1) (i) through (v) and 229.10(c)(2) only with respect to the first $5,000 of funds deposited on any one banking day; but the amount of the deposit in excess of $5,000 shall be available for withdrawal not later than the ninth business day following the banking day on which funds are deposited; and

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#1223129 - 07/28/09 12:21 PM Re: what am I missing? Reg CC question ckb
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
I'm not sure what tools you're referring to, but I've always understood that for new account holds on next day items, the amount over $5,000 can be held for 9 days. If the deposit being made qualifies for one of the exception holds (reasonable cause to doubt collectability, large deposit, emergency condition, or repeat overdrafter - I hope not yet!), then you can place that hold instead of the new account hold if it's beneficial to do so.
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#1223222 - 07/28/09 02:10 PM Re: what am I missing? Reg CC question Kelsey D
southernbelle Offline
Junior Member
Joined: Feb 2008
Posts: 31
you can extend a hold on a non-local item for 6 days ... look at 229.13(h) on what a "reasonable time" is defined to mean. the 5 day standard hold + the 6 day reasonable time for
Large Deposits
Redeposited Checks
Repeat Overdrafts
Reasonable Cause to Doubt Collectibility

Gives you an 11 day hold
Last edited by southernbelle; 07/28/09 02:12 PM.
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#1223443 - 07/28/09 04:55 PM Re: what am I missing? Reg CC question southernbelle
ckb Offline
Member
Joined: Apr 2009
Posts: 80
Thanks for the responses.

KelseyD - I am referring to the Bankers Tools section of bankersonline.com; specifically this link: Bankers Tools - Reg CC

This specific tool states that for new accounts, both local and non-local checks can get an 11 day hold. I understand why non-local checks can (southerbelle's explaination), but not why a local check would.

I'm just trying to make sure I am understanding the nuances correctly!

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#1223449 - 07/28/09 05:01 PM Re: what am I missing? Reg CC question ckb
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,801
Cape Cod
There is no specified new account hold duration for local or non-local or on-us checks. Therefore your bank gets to decide. Bonnie apparently puts an 11 biz day hold on both local and non-local checks deposited to new accounts. Your bank should adapt the tool to what your policy calls for.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1223469 - 07/28/09 05:27 PM Re: what am I missing? Reg CC question John Burnett
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
John is correct, not that I'm assuming you doubted him. A bank can set its own policy for how long it will hold local and non-local checks deposited into new accounts. Our policy is the same as Bonnie's, 11 days for both. My earlier post only addressed the rule for next day items, but I see now that you were questioning the non-next-day items. My apologies!
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1223470 - 07/28/09 05:27 PM Re: what am I missing? Reg CC question John Burnett
ckb Offline
Member
Joined: Apr 2009
Posts: 80
Thanks John - I really appreciate Bonnie's tool - and now understand it more completely!

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