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#2140318 - 08/01/17 03:02 PM New Account Hold
LSmith Offline
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LSmith
Joined: Dec 2002
Posts: 703
Reg CC states: An account is not considered a new account if each customer on the account has had, within 30 calendar days before the account is established, another account at the depositary bank for at least 30 calendar days.

Our scenario. New business opens new business account. Authorized signers have had deposit accounts personally open since 2014.

Can we invoke the New Account Hold rule or not?

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#2140322 - 08/01/17 03:08 PM Re: New Account Hold LSmith
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The "business," partnership, corporation, sole proprietorship, what?
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#2140389 - 08/01/17 06:30 PM Re: New Account Hold LSmith
LSmith Offline
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LSmith
Joined: Dec 2002
Posts: 703
The New business account is a Limited Liability Company

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#2140517 - 08/02/17 06:54 PM Re: New Account Hold LSmith
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The customer is the LLC and the LLC doesn’t have a transaction account that’s been open for 30 days or more. The LLC’s new account is a new account for purposes of the regulation.
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