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#2114646 - 01/18/17 09:52 PM RegCC - Large Deposit, Hold on 1 check
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 543
Bank is presented with three non-next day checks totaling $14676, the largest item is for $11,990 and the other two are smaller, $2,000 and 686. Bank wants to hold funds on the large item in the this deposit only. So since $2686 of this deposit is technically available to them the next business day, can we make the first $5,000 available on the 2nd business day and the remainder of $6990 available on the 7th business day? Or does the $2686 not play into the availability at all? In other words, do we still have to give $200 next day of the funds actually being held, $4800 second day and remainder on 7th day? Thanks for any help.

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#2114650 - 01/18/17 10:18 PM Re: RegCC - Large Deposit, Hold on 1 check TeamComply
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
You can aggregate the checks and you can always be more 'generous' than the regulation allows as long as you're not more restrictive.

I would aggregate the deposits, give the $2,686 the next day, give $2,314 the second business day (totaling the first $5,000 that has to be made available by that time, and hold the remaining $9,676 until the 7th day (presuming your funds availability policy allows exception holds).
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#2114652 - 01/18/17 10:31 PM Re: RegCC - Large Deposit, Hold on 1 check Doug Hendrickson
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 543
Thanks for the reply Doug.

So if the employee handling this transaction did it this way, its not technically wrong, since its more generous to the customer?

$2686 next business day, $5,000 available on the 2nd business day and the remainder of $6990 available 7th business day.

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#2114706 - 01/19/17 04:13 PM Re: RegCC - Large Deposit, Hold on 1 check TeamComply
Bankwoman1 Offline
Diamond Poster
Joined: Dec 2015
Posts: 1,064
Midwest
Yes....it's ok to give the customer more than the $200 required in the regulation.

You have already provided the customer with $2686 of the first $5000. So all you need to make available on the 2nd business day would be $2314. You can hold $9676 until the 7th business day.

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