I am not the only person confused about some 12/12/09 date. CAn I assume that we will be notified by the Feds when the whole business on non-local goes away and, then, after that, we should send out any clarifications to our policy, if necessary? Otherwise its business as usual until then....RIGHT??

After the Philly consolidation into cleveland on 12/12 - there's still the Atlanta district that will need to be consolidated into Cleveland. Once that's announced and final, then there will be only local checks. This will require a change to your Reg. CC policy.

Atlanta is scheduled for first quarter, 2010. Since they have been consolidating one per month, look for January.

UMMMM. Ok. So, with the Philly into Cleveland consolidation, did any routing numbers change??? We are a Philly bank.

From BOL's Reg. CC appendix A:

FOURTH FEDERAL RESERVE DISTRICT
[Federal Reserve Bank of Cleveland]

Head Office

[Editor's Note: 1214 and 3214 routing numbers are assigned to the "Pacific island banks" described in § 229.43 of the Regulation. They are not listed here because those banks don't meet the definition of "bank" in § 229.2, and checks drawn on those banks are not subject to Subpart B of the regulation.]

0110 2110
0111 2111
0112 2112
0113 2113
0114 2114
0115 2115
0116 2116
0117 2117
0118 2118
0119 2119
0210 2210
0211 2211
0212 2212
0213 2213
0214 2214
0215 2215
0216 2216
0219 2219
0220 2220
0223 2223
0260 2260
0280 2280
0310 2310
0311 2311
0312 2312
0313 2313
0319 2319
0360 2360
0410 2410
0412 2412
0420 2420
0421 2421
0422 2422
0423 2423
0430 2430
0432 2432
0433 2433
0434 2434
0440 2440
0441 2441
0442 2442
0510 2510
0514 2514
0515 2515
0519 2519
0520 2520
0521 2521
0522 2522
0540 2540
0550 2550
0560 2560
0570 2570
0710 2710
0711 2711
0712 2712
0719 2719
0720 2720
0724 2724
0730 2730
0739 2739
0740 2740
0749 2749
0750 2750
0759 2759
0813 2813
0830 2830
0839 2839
0863 2863
0910 2910
0911 2911
0912 2912
0913 2913
0914 2914
0915 2915
0918 2918
0919 2919
0920 2920
0921 2921
0929 2929
0960 2960
1010 3010
1011 3011
1012 3012
1019 3019
1020 3020
1021 3021
1022 3022
1023 3023
1030 3030
1031 3031
1039 3039
1040 3040
1041 3041
1049 3049
1070 3070
1110 3110
1111 3111
1113 3113
1119 3119
1120 3120
1122 3122
1123 3123
1130 3130
1131 3131
1140 3140
1149 3149
1163 3163
1210 3210
1211 3211
1212 3212
1213 3213
1220 3220
1221 3221
1222 3222
1223 3223
1224 3224
1230 3230
1231 3231
1232 3232
1233 3233
1240 3240
1241 3241
1242 3242
1243 3243
1250 3250
1251 3251
1252 3252

Did any numbers change? Last week, "local" to you was technically most of the Northeast. Today, you have to consider "local" every bank except those in the Southeast that are listed under Atlanta in Appendix A. Click HERE for Appendix A.

What about The Western states, i.e. Calif?

What about The Western states, i.e. Calif?

local

Trees - you need to look at the routing numbers that Waldensouth stated. Those are all local for you now.

OK. Got it!

Is anyone going ahead and revising their disclosures, signage now in anticipation of no longer having non local holds? Or should we expect (hope and or pray) for guidance from the Federal Reserve?

I am in the process of revising our policy and disclosure statement. I'll also take a look at our signage and ensure that it mirrors the new policy/disclosures.

ditto

So, I would like to know how you are revising your disclosures with respect to holds, i.e. I believe we can still use the "exceptions", i.e. amounts greater than $5,000......however, as ever check will be local, what kinds of holds can we use??? Can we still use a blanket 5 day hold for all checks, regardless of amount, as long as we notify customers (posters,disclousres) that we are doing so?? I hate hate hate this change!!!

You can still use all the normal reasons for excpetion holds which include large deposits (in excess of $5K), redeposited checks, repeated overdrafts, reasonable doubt/cause, emergency conditions or new accounts. As all checks will be local when Atlanta joins in, the maximum number of days for an excpetion hold (you may have different rules for a new account) is 7 business days.

You still have the opportunity to use case by case, however you are limited to 2 business days.

What is the the "blanket" 5 hold you refer to?

We are revising all of our disclosures to reflect these changes however we are not implementing the change until the last possible moment.

We're a case by case bank, so far anyways. I see from your response that we are now limited to two days for these. Thats not nearly long enough to catch a potential fraudulent check. So, as we are trapped into shortening our holds and as the frequency of bad checks just keeps growing, how are you responding to this? You can't be putting them all through collections - customers would be up in arms....Any solutions you want to pass along would be appreciated.

What kind of frequency of bad checks do you have??

With the number of paper checks being negotiated going down, how are yours on that great of an uptick?

I am just making everything local for the first or Feb and be done with it, it is not worth the repeat notifications

Just Jay asks a very valid question. We have always had next day availability and would use case by case holds more so than exception holds however our losses are relatively low.

If you can discover where your losses are occuring then you can focus your efforts in that area rather than trying to focus on the big picture when you may only need a snap shot.

Wait! There's hope. Either I was hallucinating or there was a news clip on TV last night about some group pushing for the elimination of check payments altogether by 2018! Can you hold on to your sanity for that long?

Unfortunately, it was from the Payments Council which is a consortium of financial organizations that develop strategic plans for the payment systems used in the UK.

I know of no such initiative in the US, but would be interested if true.

It is for England and Northern Ireland; other countries are also exploring such a move.

http://www.paymentscouncil.org.uk/media_centre/press_releases_new/-/page/855/

So, then everything would be either ACH or ATM??? I'd rather deal with checks than Reg E and electronic payments.