Currently, we only use exception holds. Our Reg CC policy has now been updated to include ALL of the hold types available to us within the regulation. We are still going to be a next day available bank, so really the only thing that is changing is the increase in hold options available. I am trying to get together a notification of this change ready for our statement messages. Is simply stating that "Effective (date), 2016 Bank Name will be changing our Funds Availability Policy to include all holds available by Regulation CC." While I would think we need to go into a little more detail, there is only so much room on the statement message spec.
Any advice?

to include ALL of the hold types

What other holds types are there? Does you disclosure not cover normal non-exception holds??

The only holds our disclosure covered were the following:

We believe a check you deposit will not be paid
You redeposit a check that has been returned unpaid
You have overdrawn your account repeatedly in the last six months
There is an emergency, such as failure of communications or computer equipment.

Our policy now includes:
Second-Business day/Case-by-Case Availability
Exception Availability

So before we only used the exception holds, now we are incorporating the Case-by-Case and special rules for new accounts.

That is an option allowed in the regulation, Randy.

Bec, "All the holds types available by Regulation CC" won't cut it. I don't think you can use a statement message to accomplish the notification requirement in this case, because you are going to have to spell out your policy in more detail that "all types available."

To figure out what you have to say, compare your old Reg CC disclosure with the updated disclosure, which will need to look something like Model form C-3, adapted to remove the stuff related to non-local checks and change the $100 next day amount to $200. Highlight all the verbiage that's different. That's what has to be in your notice.

It might just be simpler to create a copy of the new disclosure, with the added verbiage highlighted, and "stuff" statements with it, and include a statement message saying something like, "Effective (date), our Funds Availability Policy will change. See the enclosure, on which changed provisions are highlighted."

Thank you John, you're right, it might be to robust of a change to expect to address it all in a statement message. I like the idea of alluding to the changes on the statement message and then include the enclosure. Thank you for the great guidance.

Follow up. For the notification, would it be ok if only the new things were addressed in the policy or should it be explained that prior to the change this is what was done and now we will do it like this...?

Thank you

You can limit the notice to what is being changed or added to the policy.

Thanks again!