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#2212021 - 04/24/19 08:39 PM Case-by-Case Hold and Large Deposit Hold
Likes to Comply Offline
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In the mountains
When using a Large Deposit Hold, can a case-by-case hold be placed on the first $5,000 on any type check and give $200 next day and $4,800 2nd day or must you look to the rules for Next Day or Second Day items and apply those no matter what?

For example - U.S. Treasury Check for $15,000 deposited in the account of the payee - which is correct?

A. $200 next day, $4,800 2nd day, $10,000 7th day

or

B. $5,000 next day, $10,000 7th day
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Operations Compliance
#2212041 - 04/25/19 11:20 AM Re: Case-by-Case Hold and Large Deposit Hold Likes to Comply
Adam Witmer Offline
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B. The first $5,000 of a next day item is subject to next day availability.

From the commentary to 229.13(b):
"C. 229.13(b) Large Deposits
1. Under the large deposit exception, a depositary bank may extend the hold placed on check deposits to the extent that the amount of the aggregate deposit on any banking day exceeds $5,000. This exception applies to local and nonlocal checks, as well as to checks that otherwise would be made available on the next (or second) business day after the day of deposit under §229.10(c). Although the first $5,000 of a day's deposit is subject to the availability otherwise provided for checks, the amount in excess of $5,000 may be held for an additional period of time as provided in §229.13(h). When the large deposit exception is applied to deposits composed of a mix of checks that would otherwise be subject to differing availability schedules, the depositary bank has the discretion to choose the portion of the deposit to which it applies the exception. Deposits by cash or electronic payment are not subject to this exception for large deposits."
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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.
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#2212047 - 04/25/19 01:02 PM Re: Case-by-Case Hold and Large Deposit Hold Likes to Comply
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Posts: 1,109
In the mountains
So B then is the correct answer.
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#2212050 - 04/25/19 01:15 PM Re: Case-by-Case Hold and Large Deposit Hold Likes to Comply
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
Yes.
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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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