All-

Wondering how your banks are going to handle risk mitigation for the increase to the Reg. CC threshold for notices on return items from $2,500 to $5,000. Are your banks revisiting your hold policy such as converting from a case-by-case hold policy to a hold all policy? Doing a deeper review on larger items and maintain a case-by-case policy? Waiting to review any impact on losses and being reactionary instead of proactive? We have been having meetings around the changes and we wanted to see how other banks are handling this potential increase in losses.

Thanks.

Rather than seeking the opinions of others, look at your large dollar returns for the last two - three years and determine whether the change would have generated a loss based on your actual experience.

This mechanism has never worked well and the returning bank is not subject to strict liability for a delay anyway...

If you don't have a large volume of large $ returns that translate to losses, then why change to hold all?

Risk of loss is not necessarily the amount of the check; it is the check in relation to the YTD average balance of the account, the length of time the account has been open, and whether the customer has $ in savings or CDs and can cover the check if it is returned.