I have a customer depositing an "official check" into their account (drawn off another financial institution). Can I still place a hold on the check or does it have to be next day availability? The check is over $5,000.

I believe you would have to make the first $5,000 available the next day and the reaminder can be held until the 7th business day.

My understanding is that an "Official Check" is a item that should be made available same/next day.

The term "Official Check" does not appear in Reg CC. A check drawn by a financial institution drawn on another financial institution would meet the definition of a "Teller's Check." Unless you invoke one of the exception holds in Section 229.13, a Teller's Check is one of the mandatory next day items described in Section 229.10.

REG CC commentary .13(b) states the large deposit exception applies to checks that otherwise would be made available on the next day after the day of deposit under.10(c). The 1st $5000 would be subject to the availability otherwise provided for checks and the amount over $5000 may be held for an additonal period of time as provided in .13(h).

I read that as saying that if this is a next day item you must release $5000 the next day and the remainder could be held for the extended period of time.

If you look at the large deposit example for a next day item in the FDIC compliance manual it shows $200 should be available the next day and $4900 the 2nd day and the remainder on the 7th day. That just does not make sense to me! I emailed FDIC for an explanation but did not receive a reply. Can someone explain that to me? The example does not include any local checks-just the next day item.

Their large item charts are all wrong. If you notice, the large item exception chart concerning "on-us" checks that directly follows the chart that you are referring too also indicates that if the "on-us" check is a "non-local"?? item, the time frame for the hold would be $200 next day, $4,900 the 5th day and the remainder on the 6th day.

Really now???

Somebody was really lazy in the update. All the large item exception charts still refer to the $4,900 figure. If you make a mistake and they want to cite you for it, just tell them you where using their manual for training purpose and watch the look on their faces

The FDIC's charts on holds have been wrong since the day they published them. It's been called to their attention countless times, yet they haven't updated them. Strange, but true.

Thanks guys!

I got excited about finding flow charts-then I noticed the $4900 issue and thought FDIC just forgot to make that change when they changed the $100 to $200- After I started reading the rest of it I really started wondering why this was in the manual!
Thanks for your input. I think I will do my own flow chart!