Does the new proposed amendment to Reg CC change the number of days for a new account hold?

No. Section 229.13(a) is not altered in any way.

We are going to implement the first $200 availability prior to July 21. Does anyone have an idea of what they may put on their statements to comply with the notification requirement?
Also, we generally make funds available the same day,so this would impact occasional case-by-case and large deposit holds.

Any suggestions would be appreciated.

I basically took two sentences out of the Reg CC policy statement and then added additional to let them know that longer delays may apply.

Effective 07/21/11: Depending on the type of check that you deposit, funds may not be available until the second business day after the day of your deposit. The first $200 of your deposit, however, may be available on the first business day after the day of your deposit. In some instances, longer delays may apply.

Am I correct in thinking on the deposits over $5,000.00 if we make $200.00 available next day, then we will only be required to make $4,800.00 on the second business day after the date of deposit?

That's how I understand the rules. Currently the 2nd day availability amount would be $4,900 with the $100 next day available.

So only the proposal is out but compliance is still expected on July 21st?

I really hate to write policies, procedures and disclosures based on a proposal because they always seem to change up something that renders all of the preliminary work obsolete.

Been there, done that, discarded the T-shirt already.

The $100 --> $200 change is mandated by law and must be accomplished by 7/21/11 whether or not the current proposal is finalized.

We do have two different things here don't we? The change to $200.00 is from Dodd-Frank and the change to timeframes is still a proposal on which they are taking comments. They will give us time to comply if the proposal on the new timeframes is finalized.

I guess now is a good time to be in the disclosure printing business.

The next few years will be ka-ching time as all the little time-bombs in Dodd-Frank go off and the Bureau starts getting serious in its mission to create meaningful and informative consumer disclosures.

We want to stop providing $100 immediate avilability to atm deposits. They are on site ATMS.
Can we stop providing immediate access to ATM deposits or do we have to increase the immediate access to the $200?
We have too many empty envelopes fraud.

Regulation CC does not currently require you to provide immediate availability on ATM deposits, even cash deposits. At minimum, you can make all ATM deposits available on a next-day basis without worrying about whether the proposed rules or the Dodd-Frank increase to $200 will make you change anything later.

John, just to clarify, even though the proposed rule gives a 12 month compliance date, the law requires compliance with the $200 availability change by 7/21,11, correct? These folks drive me crazy! The quotation is from the Board's proposed rule' and the $200 change is contained in subpart B.

"In order to minimize the compliance costs, the Board proposes that banks would have 12 months to comply with the amendments to subpart B and the model forms in appendix C."

Thanks!

Correct on the change to $200. That date is 7/21/11 even if the proposed rule isn't finalized by then. It's independent of any changes to the regulation.

I see a lot of white-out and/or stickers being used on existing disclosure stock. I mean, why reprint to change $100 to $200 if you're going to need to reprint a short while later for the rest whenever it's finalized?

No one ever said compliance can't be tacky.

Gee, you're really going to like the part where they talk about periodically adjusting the $200 for inflation...

Does the change from $100 to $200 have any effect of whether institutions can eliminate the $4900 on the second business day on deposits over $5000 ....

Since you can only hold the excess of $5,000 for an exception hold, it would mean that you would hold $4,800 (on the second day case-by-case hold), rather than $4,900.

Thanks Doug ... I guess my question wasn't worded properly ... If we have a depositor come in with a $7000.00 check, can we give $200.00 next day and hold the remainder of the $6800 to day Five or Seven without giving them an exemption notice/letter?

I don't believe so. Only the excess of $5,000 can be held for that long (assuming you reserve the right in your funds availability policy). So the first $5,000 would have to be given next day unless you do a case-by-case hold for the 2 day limit. And an exemption notice would have to be given.

That is:
$200 next day
$4,800 2nd business day (assuming case-by-case)
$2,000 7th business day

or

$5,000 next day (assuming no case-by-case)
$2,000 7th business day


I hope this clarifies my comment and that others confirm.