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#2159262 - 01/04/18 09:33 PM Brushing Up on Reg CC
kiecan Offline
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Joined: May 2011
Posts: 23
Been out of the deposit space for some time now so I need to brush up on Reg CC. Our current Funds Availability notice (in our account agreement and posted on our website) states for all "other" checks we release $200 1st business day and $4800 next business day. Anything over $5000 goes on 4th business day. We do mail notices (online bank so no in person deposits) for the large deposit exception hold. But my confusion is around the $4800 hold, which is allowed by regulation. Is this considered a case by case hold and we should be sending notices for these deposits as well? Even though that is our standard policy? If yes, so that means any deposit over $200 at our firm we should be sending a notice? Any clarification would be helpful. Thank you.

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#2159266 - 01/04/18 09:42 PM Re: Brushing Up on Reg CC kiecan
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
If you are an on-line bank, I presume that everything is a mobile deposit. As such, those are not currently governed under Reg. CC and you should do whatever your agreement says you will do.
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#2159269 - 01/04/18 09:47 PM Re: Brushing Up on Reg CC kiecan
kiecan Offline
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Joined: May 2011
Posts: 23
we do have a processing center that folks can mail checks to.

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#2159472 - 01/05/18 09:49 PM Re: Brushing Up on Reg CC kiecan
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,796
Cape Cod
If your Funds Availability Policy disclosure says that you hold the balance of "other checks" to the second business day, you don't have to provide notice of that hold. But you will have to provide notice when you do a "large deposit exception" hold for the excess over $5,000.

Case-by-case holds are placed by banks that have general next-day availability policies in those instances in which they want the comfort of holding back availability of other than the first $200 one extra day.
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