Currently, we give the customer a hold notice that basically says this:

We are delaying the availablity of $xx from the funds deposited. The funds will be availabe to you on the __ business day after the day of your deposit. Date of ability is xx/xx/09.

We would like to amend this to only state how many business days the funds will delayed and remove the availibility date.

I can't find anything in the Reg that would prohibit this type of notice. Is anyone aware of concerns about this? I'm curious what others are doing.

I believe the only requirement is for the number of days being delayed. We provide both, as you currently do, as a matter of convenience to the customer.

You probably avoid a few phone calls from customers, but you would still technicially be within the requirements of the regulation if you remove the availability date.

Our hold notice says the following: (we do not mention specific dates). We have never had a problem with auditors or examiners.

We are delaying availability of $___________from this deposit.

These funds will be available on:

$ ________________ The next business day.

$ ________________ 2nd business day after the day of deposit.

$ ________________ 5th business day after the day of deposit.

This is also similar to the model language in the notices in Appendix C of the regulation.

The regulation itemizes the contents of the case by case and exception hold notices. It illustrates those requirements in model forms. The date the funds will be available is neither required nor is it depicted in model forms.

As a matter of personal opinion strongly held, this is the single best illustration of how a regulation and model language fail to help the consumer. The consumer doesn't know a business day from a banking day and probably isn't any more accomplished at counting them than your tellers are.

In a more user friendly world, what the consumer should actually be told is the date the funds will be available.

I second Ken's thoughts. On the flip side, however, it's a lot easier for your teller to simply put on the form that the funds will be available on the 7th business day after the banking day of deposit, and not have to worry about how to count the days. So what's easiest for your teller may make things harder for your customer to understand. Hmmmm.