Our hold area is wanting to place an exception hold on checks drawn off accounts that have previously been returned for NSF activity (different checks, so can't utilize "Redeposited Check" exception).

It seems logical to invoke the "Reasonable Cause to Doubt Collectability" exception with the reason of previous NSF activity on payor / drawee account although it is not one of the examples provided by the regulation.

Any concerns with establishing a process where we do an exception hold as noted above?

Yes, there are concerns. You would have a problem if you used the Reasonable Cause exception hold on every deposited check where the account holder had a previously returned check.

(1) In general. Sections 229.10(c) and 229.12 do not apply to a check deposited in an account at a depositary bank if the depositary bank has reasonable cause to believe that the check is uncollectible from the paying bank. Reasonable cause to believe a check is uncollectible requires the existence of facts that would cause a well-grounded belief in the mind of a reasonable person. Such belief shall not be based on the fact that the check is of a particular class or is deposited by a particular class of persons. The reason for the bank's belief that the check is uncollectible shall be included in the notice required under paragraph (g) of this section.

That said, you may be able to use the Reasonable Cause exception on a case-by-case basis, if a certain account/account holder really justifies a reasonable belief that the check will not be paid.