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#1455661 - 10/15/10 02:35 PM
Reg CC next day availability
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Platinum Poster
Joined: Mar 2008
Posts: 504
TN
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Expedited Funds Availability Act – Requires that next-day availability of deposits be raised to $200 from $100 and require this amount to be updated every five years based on the Consumer Price Index.
Can someone tell me when this takes effect?
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#1455663 - 10/15/10 02:37 PM
Re: Reg CC next day availability
Southern gal
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Posts: 84,326
Galveston, TX
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After they release the amendment to the regulations and then on the effective date that they set at that time.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1455674 - 10/15/10 02:49 PM
Re: Reg CC next day availability
rlcarey
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Posts: 504
TN
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#1455676 - 10/15/10 02:50 PM
Re: Reg CC next day availability
rlcarey
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Joined: Oct 2000
Posts: 40,086
Cape Cod
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The "Transfer Date" is the effective date for the amendment to the EFAA, and the Transfer Date has been defined as July 21, 2011. Prior to that date, authority and responsibility for managing Regulation CC is vested in the Federal Reserve Board; on and after the Transfer Date, the Board shares the authority and responsibility with the Director of the new CFPB.
If the Board issues a proposed and final rule amending the $100 next day amount, you can be reasonably sure that the effective date won't be prior to 7/21/11. If the Board delays action, it's possible an amendment won't be proposed for a while, until the Director is in office and up to speed. But I look for something to be effective very soon after 7/21/11 in any event.
Note: Just in case you don't read further in this Thread, it has become clear since this post was made that the change to $200 next day availability will be effective on the Transfer Date (set at 7/21/11) whether or not there is an amendment to the regulation. The DFA provision amended the EFAA as of the Transfer Date, and that will be the law then, regardless what the regulation says.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1459901 - 10/27/10 01:05 PM
Re: Reg CC next day availability
John Burnett
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Power Poster
Joined: Nov 2008
Posts: 4,132
Somewhere in the middle
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So, the change to $200 next day availability will begin 07/21/2011?
Last edited by DD Regs; 10/27/10 01:05 PM.
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#1460000 - 10/27/10 02:51 PM
Re: Reg CC next day availability
DD Regs
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Cape Cod
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DD, as I tried to explain one post above yours, you can't put a firm date on it because we don't know who will propose and finalize the amending rule, or when it will be done. I think it will be sometime on or after 7/21/11, but I can't pin it down any closer than that.
Note: It has since become clear that the change will be effective on the Transfer Date, whether or not the regulation is updated.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1460011 - 10/27/10 03:01 PM
Re: Reg CC next day availability
John Burnett
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Posts: 20,656
The Swamp
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::slaps DD:: Get with the program, Son!
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#1515801 - 03/01/11 03:24 PM
Re: Reg CC next day availability
RR Joker
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Diamond Poster
Joined: Mar 2002
Posts: 2,280
Far from Calif
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Just want to confirm that we still don't know for sure the date, yet, right? Making sure I haven't missed something since I've heard from others the last couple of days that this is for sure a change as of 7/21 (but I don't recall seeing a proposal or final rule yet).
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#1515881 - 03/01/11 04:57 PM
Re: Reg CC next day availability
CalifDreamin
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Joined: Jul 2001
Posts: 84,326
Galveston, TX
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Technically, the amendment will become efffective on the transfer date and you might was well start preparing for it. The Fed could just issue the amendment to the regulations in final form at anytime, as all they can really do is change the $ amount anyway. They still have 4 months.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1517407 - 03/03/11 09:30 PM
Re: Reg CC next day availability
rlcarey
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Diamond Poster
Joined: Nov 2004
Posts: 2,310
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See my post in this thread for a Reg. CC proposed rule that the FRB just announced.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#1518098 - 03/07/11 04:07 AM
Re: Reg CC next day availability
Reads Regs
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Cape Cod
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In the document the Reads Regs linked to, the Fed says that banks will have to comply with the increase to $200 on or before 7/21/11 whether or not the regulation is amended by then.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1542721 - 04/28/11 04:54 PM
Re: Reg CC next day availability
John Burnett
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Diamond Poster
Joined: Dec 2003
Posts: 1,362
Wisconsin
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I'm revising our check hold guidelines in light of the next day availability change from $100 to $200.
Currently, for a large deposit hold, $100 is made available the next business day, and $4,900 and the 2nd business day. With the change to $200, will the $4,900 for the 2nd business day remain the same, or will it be reduced to $4,800 so that no more than $5,000 is made available by the 2nd business day? Does this make sense?
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#1542743 - 04/28/11 05:06 PM
Re: Reg CC next day availability
CSB98
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Joined: Jul 2001
Posts: 84,326
Galveston, TX
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it be reduced to $4,800 so that no more than $5,000 is made available by the 2nd business day
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1555157 - 05/21/11 01:13 PM
Re: Reg CC next day availability
rlcarey
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Member
Joined: Aug 2008
Posts: 88
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Are you aware if the Reg CC calculator on BOL will be updated on or before 07/21/2011? I sure hope so. My tellers need this calculator!!
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#1555909 - 05/24/11 05:00 PM
Re: Reg CC next day availability
auditgirl6
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100 Club
Joined: Aug 2010
Posts: 165
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We are required to notify our customers about the change. We were planning on doing this with a statement message. Does anyone know of any sample verbage we should use?
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#1555934 - 05/24/11 05:21 PM
Re: Reg CC next day availability
rachelchri
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New Poster
Joined: Feb 2011
Posts: 12
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"Funds Availability Changes effective (Date). The first $200 of your deposit will be made available in accordance with our funds availability policy."
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#1556001 - 05/24/11 06:12 PM
Re: Reg CC next day availability
ComplianceGal2
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100 Club
Joined: Aug 2010
Posts: 165
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Thanks! And just to clarify, we can opt for a statment message instead of a mass mailing, correct?
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#1556047 - 05/24/11 07:22 PM
Re: Reg CC next day availability
rachelchri
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100 Club
Joined: Feb 2011
Posts: 128
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correct. a statement message is all you need.
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#1556050 - 05/24/11 07:26 PM
Re: Reg CC next day availability
sway
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100 Club
Joined: Aug 2010
Posts: 165
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Thank you guys for all your insight! These forums are great!
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#1556174 - 05/24/11 11:26 PM
Re: Reg CC next day availability
ComplianceGal2
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10K Club
Joined: Jul 2001
Posts: 84,326
Galveston, TX
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"Funds Availability Changes effective (Date). The first $200 of your deposit will be made available in accordance with our funds availability policy." IMHO such a statement does not amend/modify your current funds availability disclosure. You already make the first $200 (and all additional funds) "available in accordance with our funds availability policy". The statement does not change your policy by stating that the first $200 will be available the next business day.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1556222 - 05/25/11 11:15 AM
Re: Reg CC next day availability
auditgirl6
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Andy and I have reviewed the Tool, and a change is planned. We'll drop a note into our Daily Compliance Briefing when the revised tool is available.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1556232 - 05/25/11 12:05 PM
Re: Reg CC next day availability
John Burnett
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Joined: Oct 2000
Posts: 27,763
On the Net
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Yep. We are already planning changes so it will be updated as per Reg CC.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#1556482 - 05/25/11 04:20 PM
Re: Reg CC next day availability
Andy_Z
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Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
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Randy: Are you listening in on our compliance conference calls???
We had this very conversation yesterday afternoon. I tried to convince other participants that we already give out $200 in accordance with our disclosed policy; it's that policy that is changing. The consensus was that we therefore don't need to disclose. Ha! My point was that our stmt message wasn't informative.
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#1556515 - 05/25/11 05:20 PM
Re: Reg CC next day availability
Cornfed Turtle
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Power Poster
Joined: Oct 2009
Posts: 3,927
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I was reviewing our Regulation CC verbiage and noticee two things: first, we do give a copy to both demand and savings account customers, and second, it does not specifically reference transaction accounts. We have rarely, if ever, put a 'hold' on a deposit to a savings account. However, would the facts above mean that we would need to follow that funds availability policy if we did? I'm going to see if we can change both the verbiage and configure DepositPro so that it does not produce this disclosure when creating a savings account.
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#1556522 - 05/25/11 05:26 PM
Re: Reg CC next day availability
Doug Hendrickson
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Platinum Poster
Joined: Feb 2003
Posts: 962
PA
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Doug -
Our disclosures reference both checking and savings accounts and therefore we've been applying the same availability to items deposited in either type of account. I would have liked to take it out of the wording on the savings disclosure, but I don't think we had the flexibility to do so with our forms vendor.
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