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#2167639 - 03/12/18 04:27 PM REG CC-Blanket Holds
Jenny Roberts Offline
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Joined: Feb 2014
Posts: 183
Tennessee
Can some define "blanket holds" for me and how long a blanket hold can be placed? Do many banks use this type anymore?

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Deposits and Payments
#2167641 - 03/12/18 04:32 PM Re: REG CC-Blanket Holds Jenny Roberts
rlcarey Offline
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Since "blanket holds" is not a defined regulatory term - you might have to explain what you mean.
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#2167667 - 03/12/18 06:41 PM Re: REG CC-Blanket Holds rlcarey
Jenny Roberts Offline
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Joined: Feb 2014
Posts: 183
Tennessee
It is a hold where the bank decides that a hold is placed on any check over a certain amount no matter what type of check it is or who the customer is.

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#2167701 - 03/12/18 08:20 PM Re: REG CC-Blanket Holds Jenny Roberts
David Dickinson Offline
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David Dickinson
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Central City, NE
This is not allowed. You need to complete a Reg CC deposit delay on every deposit made to accomplish this.
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#2167703 - 03/12/18 08:21 PM Re: REG CC-Blanket Holds Jenny Roberts
David Dickinson Offline
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Central City, NE
I have to ask: Why would you want to do this? If it's a troubled account, maybe you should just shut down the account. To place a delay on every deposit is labor intensive.
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#2167801 - 03/13/18 03:17 PM Re: REG CC-Blanket Holds Jenny Roberts
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted By Jenny Roberts
It is a hold where the bank decides that a hold is placed on any check over a certain amount no matter what type of check it is or who the customer is.


you need to review Reg CC and what is allowed...there are 2 hold types - exception and case by case. Blanket hold is not an option. While you are reviewing what is allowed, you may also want to review the penalties that can be levied against a bank for violations. I'd hate to be the bank in court trying to defend while regulations don't apply to me...
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#2167802 - 03/13/18 03:19 PM Re: REG CC-Blanket Holds Jenny Roberts
Elwood P. Dowd Offline
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Next to Harvey
Given your terminology, the answers you received are correct.

There is such a thing as a "large dollar exception" hold. It does notapply to the entire amount of the check, only the amount above $5,000.
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#2167869 - 03/13/18 05:50 PM Re: REG CC-Blanket Holds Jenny Roberts
John Burnett Offline
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John Burnett
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Cape Cod
There is the large deposit hold under Reg CC §229.13(b). It can be applied to excess over $5,000 of all checks deposited to an account (or accounts, in the case of common account ownership). The first $5,000 in check deposits must be provided your normal availability (for other than next-day checks, you may place case-by-case holds), and the first $200 of that first $5,000 is subject to the $200 next day availability rule.

Because the large deposit hold is an exception hold, you must provide a notice to each account affected for each such hold placed except for nonconsumer accounts (under 229.13(g)(2), you can provide a one-time notice to nonconsumer accounts).

You could establish a higher threshold than $5,000 for these holds, if you wished. But you can't apply large deposit holds on the first $5,000 in checks deposited by a customer on a banking day.

The hold can only last to the second business day after the banking day of deposit for on-us checks. For other checks, funds would generally have to be available by the seventh business day after the day of deposit.
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#2167870 - 03/13/18 05:52 PM Re: REG CC-Blanket Holds Jenny Roberts
John Burnett Offline
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On reflection, the whole idea appears to be a nightmare to manage.
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#2167941 - 03/13/18 08:16 PM Re: REG CC-Blanket Holds Jenny Roberts
Jenny Roberts Offline
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Joined: Feb 2014
Posts: 183
Tennessee
Thanks everyone, I keep trying to tell the "group" that but they still want to protect the bank. I told them that unfortunately regulations are meant to protect the bank....................

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#2168176 - 03/14/18 06:38 PM Re: REG CC-Blanket Holds Jenny Roberts
John Burnett Offline
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John Burnett
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Cape Cod
Banks have been managing to offer checking accounts for decades centuries without placing "blanket holds."
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#2173300 - 04/12/18 09:16 PM Re: REG CC-Blanket Holds Jenny Roberts
clinds Offline
Member
Joined: Sep 2017
Posts: 66
What about placing an exception hold on local checks, not drawn on-us or government, etc., if the total deposit is over a certain amount ($2000) and this would only apply to New Accounts, so customer would have had no other relationship?? Would this be an issue??

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#2173418 - 04/13/18 04:25 PM Re: REG CC-Blanket Holds Jenny Roberts
Sherlocked Offline
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Joined: Dec 2013
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221B Baker St.
What are the other banks in your area doing in relation to new account holds?

How many checks do you get returned that are used to open accounts? In other words, is your risk high in this area?
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