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#2023145 - 06/25/15 07:03 PM Early morning holds released at start of workday
CARM9 Offline
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Joined: Feb 2011
Posts: 112
Our evening hold processing starts with holds being placed in the wee hours of the morning, no funds are made available. By 9 am the item may have a hold on the it, however, for local items $200 is made available. If throughout that business day we then determine no hold needs to be placed due to contacting the maker or maker bank, if we release the hold in the same day do we need to send a notice of hold since "intraday" the client does not have access to the funds other than the $200?

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Deposits and Payments
#2023153 - 06/25/15 07:11 PM Re: Early morning holds released at start of workday CARM9
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,596
Galveston, TX
You place mandatory holds on all deposits?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2023159 - 06/25/15 07:19 PM Re: Early morning holds released at start of workday CARM9
CARM9 Offline
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Joined: Feb 2011
Posts: 112
Not all deposited items, only those that alert in our system under the exception rules or other if they meet specific parameters.

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#2023163 - 06/25/15 07:23 PM Re: Early morning holds released at start of workday CARM9
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,596
Galveston, TX
So when do you mail the customer a notice of hold??
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2023165 - 06/25/15 07:26 PM Re: Early morning holds released at start of workday CARM9
CARM9 Offline
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Joined: Feb 2011
Posts: 112
If the hold remains it goes out in the mail the business day after the hold was place. We also send an email alert notifying the customer that a hold was placed.

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#2023171 - 06/25/15 07:32 PM Re: Early morning holds released at start of workday CARM9
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,596
Galveston, TX
Wow. I really am at a loss. I have never heard of a bank processing holds in this manner. What funds availability model disclosure from Appendix C are you providing your customer at account opening?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2023185 - 06/25/15 08:06 PM Re: Early morning holds released at start of workday CARM9
CARM9 Offline
100 Club
Joined: Feb 2011
Posts: 112
C2

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#2023196 - 06/25/15 08:16 PM Re: Early morning holds released at start of workday CARM9
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,596
Galveston, TX
You tell your customers that funds will be available the next day on all items, unless an exception applies. What information comes to light to the bank overnight that you don't have when the customer makes the deposit in-person at the teller window that allows you to not give a notice of hold right then and there??

229.13(g): The notice shall be provided to the depositor at the time of the deposit, unless the deposit is not made in person to an employee of the depositary bank, or, if the facts upon which a determination to invoke one of the exceptions in paragraphs (b) through (f) of this section to delay a deposit only become known to the depositary bank after the time of the deposit.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2023360 - 06/26/15 03:40 PM Re: Early morning holds released at start of workday CARM9
CARM9 Offline
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Joined: Feb 2011
Posts: 112
We have specific parameters that cause certain items to flag for a hold review, for example the branch may not know if the customer has had previous returned items or repeated overdrafts, depositing in the ATM or mobile channels that are not in person to an employee of the bank. If during that review we suspect an item is counterfeit, altered, or get an early warning, we will place a hold when those facts become known and send NOH. Others we attempt to contact makers throughout the business day to determine if a hold needs to stay on the item that was flagged for review.

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