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#1263768 - 10/08/09 05:06 PM Reg CC - Deposit vs Encashment
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Discussion abounds at work - if checks are cashed against an accountholders account, and compliance determine we need to place a hold (in the amount of the cashed checks minus $100) against the deposited funds, does Reg CC allow/authorize this? If so, can anyone help point me to a specific section within the Reg? I'm looking through there, but not finding the check cashing verbiage.....
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Operations Compliance
#1263803 - 10/08/09 05:27 PM Re: Reg CC - Deposit vs Encashment RBanker
VMack Offline
Platinum Poster
Joined: Jun 2001
Posts: 837
Texas
Look at Reg CC Section 229.19(e)Miscellaneous and the commentary to that section - E. 229.19(e) Holds on Other Funds.
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VMACK
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“The wise know their limitations; the foolish do not.”
Benjamin Hoff, The Tao of Pooh

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#1264085 - 10/08/09 08:45 PM Re: Reg CC - Deposit vs Encashment RBanker
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The reg provides for it. If your disclosure provides for it too, you're in. If your disclosure does not talk about it, you cannot do it.
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#1264101 - 10/08/09 09:00 PM Re: Reg CC - Deposit vs Encashment Elwood P. Dowd
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
If you don't provide for Holds on Other Accounts and Holds for Cashed Checks in your Funds Availability disclosure, I would strongly encourge you to review the options and think about updating your policy. Good tools to have in your funds availability toolbox.
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#1264177 - 10/08/09 09:41 PM Re: Reg CC - Deposit vs Encashment BrendaC
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
It's there - just double checked - thanks for the heads up!
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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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