MBT, the question is not common. There isn't much you can do. Technically where Reg E says to pay provisional credit it refers to the account. Still, if you forced open an account the consumer gets full use of the funds, so you'd be in the same boat, except that you'd waive any low balance fees after the consumer complains to your regulator and you create more work.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell