Look at your disclosure. The model language says:
If you are a new customer, the following special rules will apply during the first 30 days your account is open. (Emphasis supplied)
If that's what it says, then in order for your disclosure to be correct, you must impose the hold more than half the time. Depositors would not receive a hold notice at the time the hold was imposed.
Your bank may have modified the language to say:
If you are a new customer, the following special rules may apply during the first 30 days your account is open. (Emphasis supplied)
If so, you may impose the holds described in this paragraph at will; i.e. with no measure of consistency, and the customer is entitled to a notice each time a hold is imposed.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.