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#1284511 - 11/10/09 06:10 PM Re: Reg CC Changes DD Regs
Getting_Grayer Offline
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I have been reading this thread, and wondering if someone can point me to the regulatory change where it states that there will be no more non-local holds. I have the new listing of local routing numbers effective 12/11 when the Philadelphia processing center merges to Cleveland.

Any help on the regulatory change is much appreciated.

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#1284562 - 11/10/09 06:38 PM Re: Reg CC Changes Getting_Grayer
Elwood P. Dowd Offline
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You have the proof in your hands. For a nonlocal check to exist, there has to be more than one check processing region... At then end of the day Cleveland will be the Omega, the final check processing region.
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#1284620 - 11/10/09 07:11 PM Re: Reg CC Changes Elwood P. Dowd
HR Banker Offline
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Our current disclosure is the appendix C-3 model. Will we just have to change any references of "5th business day" to "2nd business day" and eliminate the routing number list? Will they provide new model language for the C-3?

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#1285002 - 11/10/09 10:43 PM Re: Reg CC Changes HR Banker
H Cody Offline
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Texas
Does the "end of the day" happen on December 12? Or are there still any regions to merge after that date?

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#1285426 - 11/12/09 05:31 PM Re: Reg CC Changes Kathleen O. Blanchard
mbj Offline
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We have used the model notice C-3 as our funds availability policy for years. Since this consolidation of check processing is being done, this is speeding up or expediting the process of funds availability. So, from Reg. CC 229.18, we have up until 30 days after implimentation to provide the notice to accoount holders. Is this correct?

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#1285657 - 11/12/09 09:03 PM Re: Reg CC Changes Getting_Grayer
Sunshine_101 Offline
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Originally Posted By: CompNewbie
. . . . . . I have the new listing of local routing numbers effective 12/11 when the Philadelphia processing center merges to Cleveland.


I don't mean to seem dense, but where are you getting the 12/11 date from and could you link to a copy of what it is you are reviewing???? The only dates I have seen for the changing of the reserves has been 10/17 and 11/14, what am I missing or where?

Please help!! Thank you in advance!!
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#1285757 - 11/12/09 10:05 PM Re: Reg CC Changes Sunshine_101
Kelsey D Offline
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Ohio
The next merge is December 12th and can be found here.
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#1285798 - 11/12/09 10:35 PM Re: Reg CC Changes Kelsey D
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Thanks!! smile
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#1285856 - 11/13/09 12:25 AM Re: Reg CC Changes Sunshine_101
Princess Romeo Offline

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It looks like the 6th District (Atlanta) is the one hold-out.

Here is the current list of check processing regions:
E-CFR Data - Appendix A of Reg. CC

As of today, the 3rd, 4th, 6th and 12th Districts are still standing. We already know the dates that the 3rd and 12th fold into the 4th District, but I haven't seen another announcement concerning the 6th.

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#1286542 - 11/13/09 09:46 PM Re: Reg CC Changes Princess Romeo
John Burnett Offline
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As noted in the version of Appendix A here in BOL's ABC Soup, at http://www.bankersonline.com/regs/229/a229a.html, Atlanta will be merged into Cleveland by the end of Q1, 2010.
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#1286681 - 11/13/09 11:06 PM Re: Reg CC Changes John Burnett
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Okay - so we have time to update disclosures and such. Thanks!
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#1291538 - 11/23/09 05:46 PM Re: Reg CC Changes Princess Romeo
comp123 Offline
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Has anyone heard of a specific date for this yet? Someone mentioned early Janaury to me but I cannot find where it states that.

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#1291550 - 11/23/09 05:54 PM Re: Reg CC Changes comp123
Elwood P. Dowd Offline
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See John's post #1286542 above. No specific date has been set, but I understand that Cleveland has told Atlanta, "You will be assimilated. Resistance is futile."
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#1291625 - 11/23/09 06:36 PM Re: Reg CC Changes Elwood P. Dowd
Random Offline
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Our lobby disclosure states that in some cases a check may be held for up to five days. Would this have to be updated if exception holds are held for that long?

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#1292059 - 11/24/09 01:40 PM Re: Reg CC Changes Random
John Burnett Offline
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If your lobby notice is patterned after model notice C-17 or C-18 in Appendix C of the regulation, it will need to be reworked when the Fed moves Atlanta processing to Cleveland or when you decide to include all checks a local, whichever comes first.
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#1292899 - 11/24/09 09:15 PM Re: Reg CC Changes John Burnett
Princess Romeo Offline

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Do you think the regulators are going to modify those model forms or amend the regulation to eliminate all of the references to non-local checks?
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#1292926 - 11/24/09 09:25 PM Re: Reg CC Changes Princess Romeo
John Burnett Offline
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I am confident that the Fed has "people" working on that. I can't guarantee that those housekeeping changes will be completed by the time the Fed has to drop Atlanta from Appendix A, but I'm guessing we'll see the changes in 2010.
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#1295514 - 11/30/09 06:02 PM Re: Reg CC Changes John Burnett
Still Complyin Offline
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If Reg CC final rule effective 12-12-09 (12 CFR 229 pg 58537 FR)
does that mean we implement by that date? I do not see a "mandatory compliance" date. What happens to our new account holds? Stay same or lesser period?

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#1295521 - 11/30/09 06:08 PM Re: Reg CC Changes VMack
mdsailor Offline
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maryland
I know this will soon be moot, but has anyone been criticized for telling customers that (i) our hold policy is based on local/nonlocal, which is based on the routing number, and (ii) please either see our website or ask us for a listing of local and non-local routing numbers?

In other words, we do make the routing numbers an integral part of the disclosure - it is available upon request.
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#1296750 - 12/02/09 01:20 AM Re: Reg CC Changes mdsailor
John Burnett Offline
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That would be a technical violation, but I have never seen a citation for it. As a practical matter, non-local won't exist by next March, so ....

InfoSponge: It means you must include Maine banks in your list of local banks (for internal use, for setting limits on case-by-case or exception holds, or for setting limits on statutory holds) by 12/12, and, if you have to update disclosures to customers because you normally hold deposits using the statutory limits in 229.12, you'll need to notify your current consumer depositors of the change by 1/11/2010.
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#1298059 - 12/03/09 05:18 PM Re: Reg CC Changes John Burnett
Still Complyin Offline
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John, to clarify, new accounts would still fall under 229.13 exceptions and excess of $5000 can be held for 9 days?

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#1298506 - 12/03/09 10:17 PM Re: Reg CC Changes Still Complyin
John Burnett Offline
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Yes. The Appendix A changes won't affect holds under ยง229.13(a).
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#1298631 - 12/04/09 12:37 AM Re: Reg CC Changes John Burnett
UFrecmgmt Offline
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Austin, TX
John,
Can the message below be considered as the proper notice language?

Effective immediately, funds deposited into your account will generally be available for withdraw the next business day. In some cases, we may delay your ability to withdraw deposited funds until the second business day after day of deposit. Direct Deposit funds will be available the day we receive the deposit.


Thank you!

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#1299070 - 12/04/09 06:03 PM Re: Reg CC Changes UFrecmgmt
kristin09 Offline
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Posts: 69
Question- We are going to consider all checks local with the most recent changes. I am working on revisions to our account disclosure (Based off model C-2). My question is whether or not in the disclosure we can get rid of the non-local check language and the disclosure of the routing numbers that are considered local? Can we just make the general statement that we consider all checks local checks and disclose the second business day requirement? Or do we still keep in the language regarding nonlocal checks and amend the five day rule to two days?

Any help would be greatly appreciated!

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#1299349 - 12/04/09 08:56 PM Re: Reg CC Changes UFrecmgmt
John Burnett Offline
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Originally Posted By: UFrecmgmt
John,
Can the message below be considered as the proper notice language?

Effective immediately, funds deposited into your account will generally be available for withdraw the next business day. In some cases, we may delay your ability to withdraw deposited funds until the second business day after day of deposit. Direct Deposit funds will be available the day we receive the deposit.


Thank you!


If you change the first "withdraw" to "withdrawal" it will be proper if it accurately reflects what your bank's policy is.
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