While doing a Reg CC review, I pulled the hold report to verify the accuracy of the expiration date of holds placed. On this particular report I noticed 2 holds that were not due to deposits. They would be exempt from Regulation CC... correct?

I would just need to verify that the holds are for other legitimate reasons.

I'm assuming that these 2 holds were for collaterol purposes, etc? If so, then you are correct, they would be exempt from Reg CC which covers deposited items.

Although checking accounts as collateral aren't the norm.

I am still looking for additional clarification from the appropriate departments. However, one states "letter for auction" I assume the loan department prepared a letter indicating customer had availability to purchase at auction a certain dollar amount. The other I am not quite sure yet.

This would be exempt from Regulation CC, correct. We all have different customer-service approaches to holding funds. I would not object to a hold on a deposit account so long as the hold is for a legitimate purpose and you disclose that you have the ability to hold funds.

Here, we hold funds after check card purchases now. And, we provide disclosures indicating this at account opening. We perform other collateral holds, too. You just need to establish a legitimate reason for the hold. I would not confuse the parameters of funds availability for deposits with other types of legitimate account holds.