We are changing our hold policy from 6 days to 7 on certain items to come in line with the regulation (I know, this may all be a moot point sometime in the future with proposed changes).

I know that Reg DD requires that you provide advance notice "if the change may reduce the annual percentage yield or adversely affect the consumer." I know this is Reg CC, but something is sticking in my mind that we would still need to give 30 days advance notice since we are adding a day to our current hold policy, technically adversely affecting the consumer. Am I confusing the two regs?

Check out Regulation CC §229.18(e) for the notice requirement.

Under your current policy, if I make a deposit on Monday and you place an exception hold, do you make the held funds available at the opening of business on the following Tuesday or the following Wednesday?

Under your new policy, when will you make the same deposit available?

Thanks, John! In your scenario above currently it would be available on Tuesday, now it is going to be Wednesday. (I think we set it up at 6 days because we thought Treasury checks were going to be treated differently and we were trying to create uniformity for the Tellers) Not sure what happened there.

As always, I really appreciate your help!

Looks good, then. I was asking about when you release the funds because there has been a historic confusion over the number of days a hold is placed for and the day on which funds must be made available. It proved to be a matter of semantics, but some banks were actually holding funds until the 8th business day in error.

I think I remember reading one of your posts about that. Thank you for double checking us!