Learn More - Click Here!

Thread Options
#1407306 - 06/23/10 07:28 PM Reg CC-New Account
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
New joint account opened, but only one of the owners has another established account. Can a new account exception hold be placed on the funds deposited in the new account?

Return to Top
Operations Compliance
#1407310 - 06/23/10 07:37 PM Re: Reg CC-New Account Southern gal
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Yes.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#1407333 - 06/23/10 08:04 PM Re: Reg CC-New Account BrendaC
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
....Assuming you make the appropriate new account holds disclosure in the Funds Availability Policy disclosure for the new account.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1407775 - 06/24/10 06:12 PM Re: Reg CC-New Account John Burnett
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
John, could you clarify that?

Return to Top
#1408003 - 06/24/10 09:20 PM Re: Reg CC-New Account Southern gal
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I don't want to put words in John's mouth, but I believe he's talking about the fact that you specifically have to reserve the right to apply exception holds (including those for new accounts and the maximum days you may hold) in your Funds Availability Policy (FAP). If you have a FAP that does not mention such holds, then you can't apply them.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

Return to Top
#1408542 - 06/25/10 08:28 PM Re: Reg CC-New Account Doug Hendrickson
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
Doug, I could not have chosen better words, so you will hear no objection from Cape Cod.

I will add an example. If your bank uses only the disclosure model form C-1 language, you don't allow for new account holds. Therefore you cannot use them. But it you use wording from a different model form (C-2, for example), you're set.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z, John Burnett