I ran into a situation where Ops put a Reg CC hold on an item for 2 days (gave customer notice at Teller line) and two days into the hold they still could not figure out if check would clear so they want to extend it to 7 days under an exception hold. I've never run across this but don't think we can do this. Any thoughts?

Thanks

What would be the exception? Paying bank was uncooperative?

I think you are permitted to do this - assuming you have a valid reason to invoke an exception hold and you notify the customer immediately of the extended hold timeframe.

Although we could not verify the checks they cleared prior to the possible placing of exception hold. Saved me from coming up with a valid exception. I like the uncooperative bank idea. Maybe we can suggest that as change for the upcoming revisions.

Thanks

I'd recommend being careful about using "uncooperative bank" as an exception reason. We use to have an exception reason of "could not verify check" and our OCC examiners said that was not a valid exception reason. They said that just because the bank would not verify the check did not mean there was a valid reason to believe that the check was uncollectible. My understanding of the regulation in relation to your original question is that an extended hold can be put on after the fact only if you become aware of additional facts that you were not aware of at the time of the deposit that makes you think the checks won't be paid. You didn't indicate that additional facts had been obtained, so I don't think applying an extended hold would be allowed.

Disclaimer:I was kind of kidding about the uncooperative bank thing.

Thats why I added the smiley!