Does anyone use the "One Time Hold"?

Yes.

You just look for those "one word answer" opportunities, don't you David?

Okay, okay... I deserved it! If any banks are using the one day hold, is it advisable? A few of our folks just attended a Bankers Compliance Group Seminar on Friday and apparently the speakers talked about the 1-day holds. Now some of the staff is asking why aren't we? They cautioned us at the seminar that, if we invoke this type of hold and notice to customer, we are obligated to actually place the hold every time on the system or we would be violating the policy we create. So, I thought this would be a good opportunity to check with other banks that use this policy and see how they monitor to ensure compliance.

Here's an excerpt from our Advanced Deposit/Operations manual on One Time Holds:
-----------------------------------------------------------
One Time Case Holds:
1. Businesses only: [Section 229.13(g)(2) - page 7418.04]
In lieu of providing a deposit hold notice for every transaction, a depositary bank that extends the time when the funds deposited in a nonconsumer account will be available for withdrawal based on a large deposit or redeposited checks exception may provide a single notice to the customer that includes the following information:

• The reason(s) the exception may be invoked; and
• The time period within which deposits subject to the exception generally will be available for withdrawal.

This one-time notice shall be provided only if each type of exception cited in the notice will be invoked for most check deposits in the account to which the exception could apply. This notice shall be provided at or prior to the time of deposit.

Model language for one time large deposit and redeposited check holds is provided in Appendix C of Regulation CC (C-14 - page 7418.36).

2. Consumer or Businesses: [Section 229.13(g)(3) - page 7418.05]

In lieu of providing a deposit hold notice for every transaction, a depository bank that extends the time when funds deposited in an account will be available for withdrawal based on the repeatedly overdrawn exception may provide a notice to the customer for each time period during which the exception will be in effect. The notice shall include the following information:
• The account number of the customer;
• The fact that the availability of funds deposited in the customer’s account will be delayed because the repeated overdrafts exception will be invoked;
• The time period within which deposits subject to the exception generally will be available for withdrawal; and;
• The time period during which the exception will apply.

This notice shall be provided at or prior to the time of deposit and only if the exception cited in the notice will be invoked for most check deposits in the account.

Model language for one time repeated overdrafter holds is provided in Appendix C of Regulation CC
(C-15 - page 7418.36).
----------------------------------------------------------

Notice that both types say:
This one-time notice shall be provided only if each type of exception cited in the notice will be invoked for most check deposits in the account to which the exception could apply.

It doesn't have to be on every deposit, but should be for most. I see few of these, but the most common is the large deposit - 1 time hold. For instance, maybe you have a business that normally brings in large deposits and then wants cash or wants to wire the money. Rather than fill out an exception hold every time, give this business a 1 time hold. This also works well for the business that frequently brings in redeposited checks.

Another example of how Reg CC is there to help bankers, but we rarely take advantage of it.

Well that was more than one word!

We all need to ask David more questions. Either I may break down and buy a copy of that manual or I'll piece it together from his answers.

Thank you David, your response is very much appreciated.

Come on Andy you have the bucks and David has proven he certainly deserves them.

By the way can I make a copy when you get it?

I just ordered a set. Let me know where to send all of the copies. JUST KIDDING, David!

Fortunately, we haven't put Jim's manuals in the mail just yet!

Well that's not very good customer responsiveness, now is it?