How are others treating payment order when processing items given the new Reg E and ODP changes? Have the examiners chimed in at all on this yet? Currently we pay checks first... largest to smallest, POS last...

Why would you pay checks first? We've never paid checks first, ATM/POS is second in line after teller cashed checks at our institution. Always has been.

You always want to pay "on us" items and contingent liabilities first, then inclearings (in whatever order you choose to pay them).

Thanks - do ya'll know if the examiners have chimed in at all on this yet?

No,direction given as a mandatory requirement for the posting order. Only a recommendation that Bank should state it in their account agreements.

The law of the land is that you can pay in an order (UCC). But the wisest plan is to pay non-returnable items (debit card, ATM card, on-us cashed checks, etc.) first.

OTS supervised institutions are advised not to pay items in an order that is intended to maximize fee income; e.g. largest to smallest.

Please, pay the items on which your bank is directly liable first and inclearing checks last. You'll live a longer and happier life.