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#123794 - 10/20/03 08:16 PM New Acct. Holds
Anonymous
Unregistered

Does it matter if you use a Case-by-case hold or Exception hold on a new account?

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#123795 - 10/20/03 08:17 PM Re: New Acct. Holds
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Use a new account hold, if you have differentiated one in your new account disclosures.
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My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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#123796 - 10/20/03 08:19 PM Re: New Acct. Holds
Anonymous
Unregistered

We don't have a hold notice specifically for new accounts...do we have to??

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#123797 - 10/20/03 08:22 PM Re: New Acct. Holds
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
If you don't have new account hold available to you, then I don't believe that you can use that as a reason for the hold - but I think I'd like to see on of our moderators weigh in on this. You would have to find a reason under your case-by-case, or exception hold notice - problem with not having a new account hold available to you, is that the other holds may not give enough time for the item to be processed.
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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#123798 - 10/20/03 09:14 PM Re: New Acct. Holds
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You probably don't have a hold notice for new deposit holds because a notice for this reason is not actually required under Reg CC.
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Life without Jesus is like an unsharpened pencil - it has no point.

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#123799 - 10/20/03 10:50 PM Re: New Acct. Holds
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Quote:

We don't have a hold notice specifically for new accounts...do we have to??



No. A new account hold requires no notice. It is in the initial disclosure that you are going to do this.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#123800 - 10/21/03 04:51 PM Re: New Acct. Holds
Anonymous
Unregistered

We just finished a Fed exam and the lead examiner who reviewed our exception hold notice form suggested that we add a box to our exception hold notice form for the new account hold. We do disclose the new account hold in our initial funds availability policy and we do provide an exception notice more for operational reasons than consumer. Our operations department reviews holds placed on accounts and the form is used so they will know why.

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