I am looking for some clarification on what hold times apply to On Us Checks which are mailed in to us? We are a virtual institution, so we have no branches. We are remote deposit and mail in only.

I read the below from the Reg and assumed we would treat it as a local check since it was not deposited in a branch.

"A check deposited in a branch of the depositary bank and drawn on the same or another branch of the same bank if both branches are located in the same state or the same check processing region"

And then I see the Reg CC Tools on BOL and assume the same thing since On Us Checks has a # and the # footnote says "If not deposited in person, (ATM mail, night drop, etc.) then this becomes a local item"

However I then found Reg CC Summary Chart on BOL and it looks like there is no difference between in person and not in person.

And Reg CC Quick Reference Guide on BOL , which includes a footnote that says "If a next-day item is deposited at the Night Drop or at an ATM, (except for U. S. Treasury checks, On Us checks, and cash), it will follow the same availability schedule as other checks.

Any guidance you can provide would be appreciated. Needless to say, I am a little confused right now. Thank you!

I don't believe you put holds on On-Us checks. You either pay it or don't depending on the availability of funds in the corresponding account.

I would look and see what your deposit agreement says regarding funds availability. I would imagine it would say something to the effect of funds for checks mailed in will be applied/deposited the business day they are received. There would also be something regarding your remote deposit policy.

While you may not have any branch offices, you still have a main office, whether depositors can access it or not. And an on-us check would be any check drawn on your bank being deposited at your bank, no matter how it arrives there.

The # next to on-us checks on the Reg CC tool on our site is incorrect. I can see how that would cause confusion. I will make a correction to that tool as soon as I am able to do so.

On-us checks other than those deposited to a non-proprietary ATM are next-day availability items. When they are deposited in a non-proprietary ATM, section 229.12(f) requires that they be available not later than the fifth business day following the banking day of deposit.

Availability of an on-us check may also be affected by an exception hold under 229.13. You can add one business day (making the funds available on the second business day after the banking day of deposit) unless the on-us check was deposited at a non-proprietary ATM, in which case you can extend the availability deadline from the 5th business day to the 11th business day following the banking day of deposit.

You da man, John!

There are no "unknowns" in connection with an on-us check; if it's in the hand of your employee, your bank is in a position to know whether it is properly payable by the next business day.

we use an outside check processor so we do place "guaranteed check holds" on our on- us items due to the 1 day lag between processing and posting. The hold matches the dollar amount and check number so when the item actually is being posted to the account the hold comes off and the checks pays.

madukes - are you taking about putting a hold on the check maker's account or someone's account who is depositing a check drawn on another account at your bank. It is not the same thing.