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#151241 - 01/17/04 01:39 AM REG CC vs. Bank Policy
Anonymous
Unregistered

My bank's hold policy is case by case with the option for the exception/extended holds. I understand that REG CC establishes the maximum allowable hold days for specific items and whether it is local/nonlocal.

My concern is this: Certain branches are placing exception holds for different days, but always to the customers benefit. For instance, instead of 7 days (2+5) for an exception/extended hold on a local check, it can be 4, 5, 6. Just dependent on the customer relationship or branch officer.

I believe it is not a REG CC violation, but if the holds are not place according to bank policy I feel it is an issue. We do state, up to x days.

I apologize for the long entry. Any guidance/insight would be appreciated.

Thanks.

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Operations Compliance
#151242 - 01/17/04 04:18 AM Re: REG CC vs. Bank Policy
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
This is not a regulatory issue. But let me ask, if you're going to put a hold on a check, why wouldn't you place the maximum amount of time on the hold? You don't get that long anyway?
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David Dickinson
http://www.bankerscompliance.com

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#151243 - 01/17/04 03:25 PM Re: REG CC vs. Bank Policy
Pup Offline
Power Poster
Pup
Joined: Sep 2003
Posts: 5,045
Pedaling along a scenic highwa...
That is simply an internal issue which we battled as well. We made it strict policy that a hold will be placed for exactly 2,5,7,11 days dependent upon the situation. For example, an 8 day hold which in a situation which qualifies for the 11 day hold is legal, but not advised.

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#151244 - 01/18/04 03:26 AM Re: REG CC vs. Bank Policy
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
In addition to reducing your exposure to returned check losses, using the maximum holds as a matter of policy results in consistency throughout your bank. Anyone who has spent time on a teller line has likely heard a customer object to a procedure with "the downtown branch doesn't do it that way." While some individual customers may object to longer holds than they're used to, your customer base as a whole will be happier knowing that they get the same level of service (and the same rules parameters) at all of your branches.

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#151245 - 01/19/04 04:25 AM Re: REG CC vs. Bank Policy
Banker Boy Offline
Member
Banker Boy
Joined: Oct 2003
Posts: 69
Florida
In my opinion, it might also be a considered a discriminatory practice with different branches having different practices with the # of days held. Branches in the same marketplace should follow the same set of guidelines, at least for the sake of consistency.

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