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#1338200 - 02/05/10 01:56 PM Reg CC hold notice on receipt
Kahola Offline
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Kahola
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Scottsdale, AZ. 85255
Branch Ops is wanting to use the deposit receipt in lieu of an actual hold notice. They say they can put all the required information on the receipt. Are there any banks out there doing this?

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#1338309 - 02/05/10 02:59 PM Re: Reg CC hold notice on receipt Kahola
Doug Hendrickson Offline
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We're not. Even though you might be able to put all the required information on the receipt, a standard form makes it very clear that you are putting a hold on the account and the availability of the customers' funds. We also use the form to send to operations to actually place the hold, which can then be reviewed by auditors and examiners for compliance.
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#1338358 - 02/05/10 03:19 PM Re: Reg CC hold notice on receipt Doug Hendrickson
Kahola Offline
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I am not sure what I am going to audit since there will not be an actual hold notice and no copy of the receipt. Branch Ops is telling me I can look at the hold report for auditing purposes. When the teller places a hold they will need show the customer how to read the info on the receipt. Then I am not sure how they will handle those situations where the hold is not placed while the customer is present or if a hold is placed on a mail deposit.

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#1338383 - 02/05/10 03:28 PM Re: Reg CC hold notice on receipt Kahola
BrendaC Offline
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Is the transaction information retained in an electronic journal or on teller tapes?
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#1338415 - 02/05/10 03:44 PM Re: Reg CC hold notice on receipt BrendaC
Kahola Offline
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The information is retained for 1 month on an electronic journal and then deposit ticket will have the hold information on the back side.

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#1338522 - 02/05/10 04:22 PM Re: Reg CC hold notice on receipt Kahola
Skittles Offline
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TN
If/when the examiners come into the bank and request your hold notices - will you be able to give the notices to the examiners? If not, I'd say no go.
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#1338820 - 02/05/10 07:07 PM Re: Reg CC hold notice on receipt Skittles
BrendaC Offline
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I've never seen a journal held for only 1 month. Is that just the Reg CC info or all teller transaction info (heaven forbid). If an electronic journal is all you have, you will have to reset parameters to retain for two years or you can't comply with Reg CC retention requirements.
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#1338889 - 02/05/10 07:37 PM Re: Reg CC hold notice on receipt BrendaC
rlcarey Online
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The regulation only requires a two year retention on exception hold notices using the "reasonable cause" exception.
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#1338902 - 02/05/10 07:40 PM Re: Reg CC hold notice on receipt rlcarey
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How would you document special situations that led to the hold that you don't necessarily disclose to the customer (that must be retained). You know, things like suspected kiting? You would definitely have to have two notice options, electronic and paper.
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#1338948 - 02/05/10 08:05 PM Re: Reg CC hold notice on receipt BrendaC
Doug Hendrickson Offline
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If we do a case-by-case (that didn't require us to tell the customer anything) we would write on OUR copy of the notice why we held the funds.
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#1338951 - 02/05/10 08:07 PM Re: Reg CC hold notice on receipt Doug Hendrickson
rlcarey Online
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But you don't need a reason for a case-by-case hold. I think that is opening a can of worms.
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#1338964 - 02/05/10 08:15 PM Re: Reg CC hold notice on receipt rlcarey
Doug Hendrickson Offline
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No, a reason is not necessary for a case-by-case hold. But even that will become a non-issue when non-local checks are eliminated and we can only hold until 2nd business day. I think we're going to retain the case-by-case language, but I've indicated to staff that after 2/27, its use should basically cease.
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#1339290 - 02/08/10 01:53 PM Re: Reg CC hold notice on receipt Kahola
Elwood P. Dowd Offline
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As noted, one concern is your ability to retain copies of the exception hold notices and perhaps notes regarding holds based on "confidential information" for the requisite two years. In addition, any third party reviewer will want to be able to review recent holds of other types, but will need a copy of the check in addition to the log you were offered in order to see if the hold is correct. The other major concern is the "general disclosure" requirement that the disclosure be "clear and conspicuous."

Regardless of the other factors, that kind of ambiguity lends itself to the evaluation of a field examiner. He or she might say that there is not enough to draw the consumer's attention to the hold notice on the receipt; i.e. how does the consumer know it's anything other than a receipt? (Good luck with saying "We point it out to them." You cannot rely on oral statements to meet paper requirements.)

I like the idea and would try to make it work, but I would not offer the proponents any assurances that it will work. Regulatory acceptance will depend on the examiner, not the wording of the regulation.
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#1339788 - 02/08/10 09:53 PM Re: Reg CC hold notice on receipt Elwood P. Dowd
OkieDokie Offline
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Our bank recently changed core processors and their teller system provides the hold notice on "receipt type" paper. We print an additional copy for our records.

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#1340443 - 02/09/10 08:49 PM Re: Reg CC hold notice on receipt OkieDokie
Kahola Offline
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Scottsdale, AZ. 85255
Okie Dokie

So are you saying that the hold notice is not a the deposit receipt but on another piece of paper, the "receipt type" paper?

Do you keep a copy of the check/s with the copy?

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#1340461 - 02/09/10 09:03 PM Re: Reg CC hold notice on receipt Kahola
Princess Romeo Offline

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I have seen a few teller systems that put the Hold Notice on the deposit receipt. The biggest draw back, as Ken pointed out, is to make sure you can keep those Exception Hold notices and documentation for two years.

From a customer perspective, it's one less piece of paper to cram into your pocket or purse, and frankly - if I want to know something about my deposit, I want to look at my deposit receipt - not a gajillion other scraps of paper.

From an audit perspective, what I have done is request a series of deposit receipts from a "Test Account" for various hold situations, and I have found instances where the system did not place all required verbiage on the notice. The institution then opens a ticket with their date processor to correct.
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#1398553 - 06/02/10 03:21 PM Re: Reg CC hold notice on receipt Princess Romeo
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Somewhere in the middle
The CU I came from put it on the receipts. We also had a place where the customer signed on the receipt. Later as the system improved, the customer signed a pad and the signature was captured on receipt and image file.

The system imaged the transaction and created a holds report. Never had a problem with any audits in the 8 years I was there.
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#1399619 - 06/04/10 02:26 PM Re: Reg CC hold notice on receipt Kahola
ledfoot Offline
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Georgia
Currently, though not much value in it, our tellers have a case by case hold notice form on their teller machines but do not have an exception hold notice form. Is it permissable to use that same hold notice for an exception hold as long as they specify the reason for the hold? It appears that the language is the same except for stating the reason for the hold. It's just that we've always used two different hold notices (CBC and Exception).
Also in reviewing Appendix C of Reg CC there is a Reasonable Cause Hold Notice model. Does anyone use that as a separate form?
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#1399646 - 06/04/10 02:54 PM Re: Reg CC hold notice on receipt ledfoot
Doug Hendrickson Offline
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We use a combined form. It has two check boxes at the top to select either (or both!) a case-by-case hold and/or an exception hold. Further down on the form is a line for the description of the hold (e.g., large dollar, reasonable cause, etc.).
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#1399684 - 06/04/10 03:15 PM Re: Reg CC hold notice on receipt Doug Hendrickson
ledfoot Offline
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Georgia
I thought you could probably use one form as long as if an exception hold is place that the reason for the hold is disclosed but just wasn't sure. Our exception hold combines includes the reasonable cause notice on it.
I think we'll be okay then.
Thanks for your help.
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