I have always been under the belief that hold notices should state the number of days until funds are available instead of the actual date that funds are going to be available. The folks at my new employers are telling me that the FDIC said they could use the actual date instead of the number of days. I can't find any written confirmation or guidance on this. Can anyone guide me to it? Or are my new coworkers just "confused".

Thanks!

Either is acceptable - see the commentary 229.16(c)(2)(c) The requirement that the case-by-case hold notice state the day that funds will be made available for withdrawal may be met by stating the date or the number of business days after deposit that the funds will be made available.

12 CFR § 229.15(b) addresses the uniform reference to day of availability. The commentary specifically says...

Banks must disclose when deposited funds are available for withdrawal by stating the business day on which the customer may begin to withdraw funds. The business day funds will be available must be disclosed as “the ________ business day after” the day of deposit, or substantially similar language.

The regulation is pretty specific, so I'd use their exact wording. However, I do encourage my employees to note the actual date off to the side so that the customer doesn't have to guess what day they can withdraw the funds. I point out to my employees that if they struggle to count the days, surely the customer will, so we do it occasionally as a customer service tool.

The section that I referred to is addressing the initial disclosure I believe, while Randy's is addressing the specific disclosure that is made on a case-by-case basis. After reading 229.16(c)(2)(c), I agree with him that both are acceptable, not that you doubted him or needed my reassurance.

Thanks to you both!