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#2185596 - 07/17/18 01:19 PM Multiple Mobile Deposits Hold
Q Offline
Member
Joined: Jun 2015
Posts: 52
We had a customer complete multiple mobile deposits on the same day and are looking to place a hold on funds. Are we able to treat the transactions as one or do we have to treat each check as separate? I am thinking it would be separate and would need a reason for each check. We treat mobile deposits same as in person deposits regarding holds. Thank you

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Deposits and Payments
#2185601 - 07/17/18 01:34 PM Re: Multiple Mobile Deposits Hold Q
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Regulation CC holds are based on all deposits made in a single business day and are never check by check.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2185635 - 07/17/18 03:05 PM Re: Multiple Mobile Deposits Hold Q
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
You can do what you want with mobile deposit holds (until the new Reg CC comes out) as they aren't currently covered under Reg CC. If you want to follow CC, you aggregate the checks made on the same business day, as Randy previously explained.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2186051 - 07/19/18 03:21 PM Re: Multiple Mobile Deposits Hold Q
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Adam's reference to the "new Reg CC" does not apply to the amendments effective 7/1/18. We are still waiting for amendments to subpart B of the regulation, which is in dire need of an update, which will almost certainly include language bringing RDC and mobile deposits under the Reg CC umbrella.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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