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#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?

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Operations Compliance
#1407310 - 06/23/10 07:37 PM Re: Reg CC-New Account Southern gal
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Yes.
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#1407333 - 06/23/10 08:04 PM Re: Reg CC-New Account BrendaC
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
....Assuming you make the appropriate new account holds disclosure in the Funds Availability Policy disclosure for the new account.
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BankersOnline.com
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#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?

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#1408003 - 06/24/10 09:20 PM Re: Reg CC-New Account Southern gal
Doug Hendrickson Offline
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Doug Hendrickson
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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.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1408542 - 06/25/10 08:28 PM Re: Reg CC-New Account Doug Hendrickson
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
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.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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