A customer makes a $500 ATM deposit on Monday at 11:00am. On Tuesday morning when we retrieve the check image (we don't get this until then) we want to place a case-by case hold on it for one day. Since a hold notice was not given (and could not be provided via the ATM obviously) can we send them a notice at that point? ie, we want to hold it until Wednesday.
My reading of the timing notice in 229.13 notes this is for exception hold notices only.
our reasoning is this: the deposit is of the type that we suspect it is fraudulent, but to this point there has not been an issue (not new customer, repeat overdraft, etc.). however, most banks will no longer tell us if a check will clear (we still do). The customer to this point has not had any issues - not new customer, repeat overdraft, etc. We generally find out Tuesday night that the if the check is good.
the challenge is our system will not let us place a hold on the check (case-by-case) for a deposit on Monday because it programs the hold to fall off Tuesday night.
any comments would be appreciated.