I don't know if I've just been looking at this too long, overthinking it or if I'm just not getting it but I have a question regarding Reg CC and electronic transfers (including wire transfers and direct deposits). I am currently looking over our Reg CC policy prior to it going in front of the board for our annual approval. As I am reading thru it I notice in the section "Types of Deposits" it states that the following deposits are made available not later than the next business day after the day of deposit: One of the items listed is Electronic transfers - including wire transfers and direct deposits.

While looking thru the Regulation on this site and reading thru some of the model disclosures and policies I noticed a section that read "Electronic direct deposits will be available on the day we receive the deposit." We do not have this in our policy anywhere. I know I have read elsewhere that wire transfers are made available on the day we receive the transfer also. But then I find in the Regulation where it states electronic funds will be made available next day.

Am I crazy or just mixing things up? Should I change our policy or leave it be?

Help!

Thanks

While many banks offer same day availability, the rule under Regulation CC is actually next day availability. You should be fine to leave your policy as is.

From Regulation CC:
(1) In general. A bank shall make funds received for deposit in an account by an electronic payment available for withdrawal not later than the business day after the banking day on which the bank received the electronic payment.

Thank you Adam! I was driving myself - and my co-worker - crazy with all of this.

Regulation CC only governs the availability of funds deposited by check and cash.

Availability of funds from wire transfers and ACH credits is governed by other legal frameworks; Regulation CC's reference to when funds from electronic deposits are available "in general" is completely, totally gratuitous.