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#1285486 - 11/12/09 06:47 PM Re: Reg. CC changes Elwood P. Dowd
Summer101 Offline
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We provide next-day availability but will invoke case-by-case and exception holds as needed.

I just want to be sure the lobby notice only needs to discuss the next-day and case-by-case second-business day time frames. It does not need to include the exception hold time frame ... which I believe will be the 7th business day once there are no more non-local checks.

Is that correct?

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#1285599 - 11/12/09 08:16 PM Re: Reg. CC changes Summer101
Brad B Offline
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KS
You are correct. The "exception" hold times are just that - "exceptions" to the "general" next-day availability policy. The notice that should be posted where employees accept deposits is the general policy. The model notices C-17 and C-18 indicate as much in my opinion.
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#1287596 - 11/17/09 12:46 AM Re: Reg. CC changes Badgerollie
AKA nan Offline
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We have decided to jump on this and just eliminate the term "non-local" now and not wait until the first qtr of 2010. I want to send a notice to our current customers, and I would like something short that I can put on a statement message. Does anyone have any idea of what the content of that notice needs to be? Is there "model" language for something like that?
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#1289062 - 11/18/09 07:30 PM Re: Reg. CC changes AKA nan
Summer101 Offline
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We are also looking for wording that will fit in the statement message field. We currently provide immediate availability but discuss the 5 business day case-by-case and 11 business day exception holds in our disclosure. We also invoke new account holds of 4 business days for local checks and 9 business days for non-local checks. We are just going to drop the line about 9 business days for non-local checks from the disclosure. I'm hoping we don't need to mention that in the change notice as the account holder would be past the point of being a new account when this change notice is sent.

What do you think of the following ...

"Funds from case-by-case holds will be available on the 2nd business day & funds from exception holds will be available on the 7th business day following deposit. Eff immediately."

Does this sound sufficient? Thanks.

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#1289081 - 11/18/09 07:39 PM Re: Reg. CC changes Summer101
VMack Offline
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Texas
I used my lobby notice verbiage with a short intro describing the reason for the change.
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#1303428 - 12/11/09 12:58 PM Re: Reg. CC changes VMack
CalifDreamin Offline
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Far from Calif
Any other statement message suggestions? We are VERY limited on statement msg length. I can't remember exactly, but it might be something like 60 characters on each line and a max of 3 lines.
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#1303643 - 12/11/09 04:09 PM All Local Checks Badgerollie
dollars & sense Offline
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Can anyone clarify that today is the day we stitch to one processing district and that makes all checks now local checks?

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#1303802 - 12/11/09 05:48 PM Re: All Local Checks dollars & sense
rlcarey Online
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No - sometime yet to be announced in the 1st quarter. After today there will still be two regions.
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#1304107 - 12/11/09 09:22 PM Re: Reg. CC changes Elwood P. Dowd
Musetta Offline
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Missouri
I just need some clarification. If we have a New Account Hold is it acceptable to still place a hold until the eleventh business day for certain deposited items? Or would this change to the seventh business day?
My Brain Hurts!!!

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#1304117 - 12/11/09 09:27 PM Re: Reg. CC changes Musetta
Kelsey D Offline
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Ohio
These changes do not affect new account holds.
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#1304146 - 12/11/09 09:44 PM Re: All Local Checks rlcarey
dollars & sense Offline
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Where can I find a routing number list of the 2 regions? I think I missed a consolidation/update along the way.

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#1304236 - 12/11/09 10:24 PM Re: All Local Checks dollars & sense
Musetta Offline
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Missouri

http://www.bankersonline.com/regs/229/a229a.html
Try Appendix A of Regulation CC.

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#1304643 - 12/14/09 02:28 PM Re: Reg. CC changes Musetta
John Burnett Offline
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Originally Posted By: Musetta
I just need some clarification. If we have a New Account Hold is it acceptable to still place a hold until the eleventh business day for certain deposited items? Or would this change to the seventh business day?
My Brain Hurts!!!


Under a new account hold, the amount over $5,000 of next-day checks can be held, but must be available by the ninth business day. Other checks (local and -- for now -- nonlocal checks and even on-us checks) have no maximum hold times under 229.13(a).

There is no currently announced plan to mess with 229.13(a).
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#1304862 - 12/14/09 04:17 PM Re: Reg. CC changes cbinder63
nancyk Offline
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CT
Can someone provide a link of where the December 11. 2009 conversion for Philadelphia is listed?

Thank you.

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#1305052 - 12/14/09 05:29 PM Re: Reg. CC changes nancyk
CalifDreamin Offline
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Far from Calif
Would a statement msg. as simple as this be okay?

Effective ______, due to changes in Federal Reserve check
processing regions, our hold policy has changed to reduce
the number of days a hold may be placed on a check.
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#1305104 - 12/14/09 05:58 PM Re: Reg. CC changes nancyk
John Burnett Offline
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Originally Posted By: nancyk
Can someone provide a link of where the December 11. 2009 conversion for Philadelphia is listed?

Thank you.


http://www.bankersonline.com/topstory/74fedreg/74FR58537.pdf
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#1305293 - 12/14/09 07:31 PM Re: Reg. CC changes CalifDreamin
rlcarey Online
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The only person qualified to opine on that would be your legal counsel.
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#1310004 - 12/21/09 03:02 PM Re: Reg. CC changes rlcarey
asanders Offline
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Regarding the Reg CC changes, can someone clarify if our newly revised Funds Availability Disclosure are required to be in a printed paper format and delivered to our customers or can we place a reference to our website on the statement and place the newly revised Funds Availability Disclosure there. Would this be compliant? And what is the time frame this must be disclosed?

Thanks!

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#1310269 - 12/21/09 05:31 PM Re: Reg. CC changes asanders
John Burnett Offline
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If you have made a change in your Funds Availability Policy that speeds up availability for consumer accounts, you are required to provide a notice to those consumers no later than 30 days following implementation of the change. [229.18(e)] That notice must be in writing and in a form the consumer can keep. [229.15(a)]

The notice may be delivered electronically to a consumer only if the consumer and bank have complied with the requirements of the E-SIGN Act, which require a demonstrable consent from the consumer.

You don't need to deliver your whole FA disclosure; you can simply notify the consumer of what the changes are.
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#1311335 - 12/22/09 04:14 PM Re: Reg. CC changes Badgerollie
danyielg Offline
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OK
after reading all the threads thus far, I still have one last question. are mail deposits also going to be next day availabilty? or should they be 2nd day?

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#1350610 - 03/01/10 07:47 PM Re: Reg. CC changes danyielg
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Somewhere in the middle
I have a question about "State and Local Governemnt Checks". With the change in processing districts, are all State and Local Government Checks now next day items? Or could you say only those that are in the state that we currently have offices in?

For example, if we are in Ohio and some one has a check from Bakersfield Ca, are we to treat it as next day or could we treat it as "local check".

I am curious based on this part of the reg.

Sec. 229.10 Next-day availability
(C) Certain check deposits--(1) General rule
(iv) A check drawn by a state or a unit of general local government and deposited--
(A) In an account held by a payee of the check;
(B) In a depositary bank located in the state that issued the check, or the same state as the unit of general local government that issued the check;
(C) In person to an employee of the depositary bank; and
(D) With a special deposit slip or deposit envelope, if such slip or envelope is required by the depositary bank under paragraph (c)(3) of this section.
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#1350906 - 03/02/10 02:25 PM Re: Reg. CC changes DD Regs
John Burnett Offline
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When you consider that the ONLY change to Regulation CC is that all of the bank routing numbers have been relocated under the Cleveland Federal Reserve Bank, and that change effectively eliminates nonlocal check references throughout the regulation, there is nothing at all that affects the wording in 229.10(c)(1)(iv).

For example (and this is strictly a hypothetical situation), if your bank branch in Kentucky accepts a check issued by the city of Louisville, KY, that's a local government check, even if the check is drawn on a bank in New York, NY. It gets next-day treatment if deposited with a special deposit ticket by a payee of the check, with an employee of the bank.

But if the same check is deposited in your Ohio branch office, it's not a local government check, and you could give it second business day availability.
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