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#1696871 - 05/08/12 03:23 PM Reg CC - Lobby signage
KYWoman Offline
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Joined: Feb 2008
Posts: 63
Kentucky
Difference of opinion on whether or not signs are required at teller stations concerning availability of deposits. We no longer have a 2:00 cut-off time for deposits, as our end of day is at close of business except for Saturday deposits, which will post on Monday. Right now, we only have the one Notice of Funds Availability Policy posted in the lobby, which is off to the side, not at the teller windows. This is Reg CC 229.18. Your response is appreciated.

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#1697132 - 05/08/12 08:34 PM Re: Reg CC - Lobby signage KYWoman
Irishguy Offline
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Irishguy
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Kentucky
This is from the commentary to 229.18:

B. 229.18(b) Locations Where Employees Accept Consumer Deposits

1. This paragraph describes the statutory requirement that a bank post in each location where its employees accept consumer deposits a notice of its availability policy pertaining to consumer accounts. The notice that is required must specifically state the availability periods for the various deposits that may be made to consumer accounts. The notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits. For example, the notice might be posted at the point where the line forms for teller service in the lobby. The notice is not required at any drive-through teller windows nor is it required at night depository locations, or at locations where consumer deposits are not accepted. A bank that acts as a contractual branch at a particular location must include the availability policy that applies to its own customers but need not include the policy that applies to the customers of the bank for which it is acting as a contractual branch.

The sign just has to be located where the depositor is likely to see it. Hope this helps!

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#1697236 - 05/09/12 11:59 AM Re: Reg CC - Lobby signage KYWoman
Elwood P. Dowd Offline
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The only person who thinks you must post a lobby notice at each teller window is the guy who sells them.
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#1697266 - 05/09/12 12:51 PM Re: Reg CC - Lobby signage KYWoman
KYWoman Offline
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Joined: Feb 2008
Posts: 63
Kentucky
Thanks for your help! Found that out, too!

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#1697520 - 05/09/12 04:39 PM Re: Reg CC - Lobby signage KYWoman
Snowgirl Offline
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Joined: Sep 2003
Posts: 729
We actually got in trouble for not having the short version of our policy posted on the front of our teller row (not at each window, just on the front of the teller row, so we now have our full disclosure on the wall of the lobby along with a shortened version on the front of teller row and on the new accounts desk.

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#1698740 - 05/11/12 04:37 PM Re: Reg CC - Lobby signage KYWoman
Andy_Z Offline
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We had what some of people referred to as a "rope-a-dope" system in front of the teller line - the poles and ropes that snake your customers up to the next available teller. One of those poles had a bracket mounted to the top and in that bracket was our disclosure.
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