While conducting a Reg CC review I noticed an extended/indefinite hold on a business savings account. The hold was placed as a condition for approval for ACH origination. According to the credit review the originator is a newly formed company and the hold on the savings account is collateral for the ACH origination. The hold will be released once the originator has established their ACH origination relationship with us. The only items I see in the originator's file approving this arrangement are our internal emails that state this arrangement was discussed with the originator.

I think we should execute an Assignment of Deposit Account form that the originator signs so we have written documentation of this arrangement. I'm curious as to what my fellow BOL'ers think of this suggestion.

Bump

We add wording to the contract they sign that references the hold on an account and when we will review the account for possible release of the hold.

Sounds like pre funding of Originated entries. Check out the ACH Rule book. This is common practice for risk based cash management files when you have a new or higher risk originator.