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#2212429 - 04/30/19 03:51 PM
Courtesy Holds
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100 Club
Joined: Jan 2007
Posts: 179
Kentucky
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Just curious if anyone does Courtesy Holds?
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#2212431 - 04/30/19 03:54 PM
Re: Courtesy Holds
Linkpars
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Power Poster
Joined: Nov 2004
Posts: 6,724
Illinois
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What is a courtesy hold? That is not a term that is mentioned in any regulation.
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#2212434 - 04/30/19 03:59 PM
Re: Courtesy Holds
Linkpars
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100 Club
Joined: Jan 2007
Posts: 179
Kentucky
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Just a 1-2 day hold, we have always called them courtesy holds.
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#2212439 - 04/30/19 04:11 PM
Re: Courtesy Holds
Linkpars
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Power Poster
Joined: Sep 2010
Posts: 2,662
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As Brian said, that isn't a term in the regulation and I have never heard of that term before, though it sounds like it could be what we typically referr to a "case-by-case hold". Is this a hold on a checking account and do you use any other types of holds?
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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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#2212446 - 04/30/19 04:24 PM
Re: Courtesy Holds
Linkpars
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10K Club
Joined: Jun 2004
Posts: 19,858
Pulling people out of the ditc...
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i can see this being explained to a customer...
customer - why is there a hold on my deposit? banker - oh, that is a courtesy hold, you will have your money available in 2 days customer - do you know what the word "courtesy" means? this is no courtesy to me...
but anyway, sounds like case by case hold to me as well
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#2212447 - 04/30/19 04:26 PM
Re: Courtesy Holds
Linkpars
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100 Club
Joined: Jan 2007
Posts: 179
Kentucky
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They could be considered case-by-case holds. We just do these as a courtesy hold usually for 1 day, sometimes 2. I was just wondering if anyone else does these and if you limit the dollar amount on these.
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#2212452 - 04/30/19 04:40 PM
Re: Courtesy Holds
Linkpars
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Power Poster
Joined: Sep 2010
Posts: 2,662
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Case-by-case holds are very common and used frequently by other institutions.
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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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#2212453 - 04/30/19 04:41 PM
Re: Courtesy Holds
Linkpars
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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Curious - why do you place these courtesy holds - and are they effective?
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#2212454 - 04/30/19 04:42 PM
Re: Courtesy Holds
Linkpars
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Power Poster
Joined: Sep 2010
Posts: 2,662
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When I hear "courtesy" it makes me wonder if these are customer requested? If that is the case, you may be able to use the reasonable cause exception in some cases (where the customer thinks the check may bounce).
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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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#2212456 - 04/30/19 04:50 PM
Re: Courtesy Holds
Linkpars
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100 Club
Joined: Jan 2007
Posts: 179
Kentucky
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I am not sure where the term courtesy hold came from, but I have been here for 25 years, and that is what they have always been called. I see the hold as not being under the Reg CC terms, if we hold an item for just one day. If we would chose two days then the item would fall under Reg CC as a standard hold (2-5) days.
Our Compliance Dept. told me that if we placed a courtesy hold that it could not be over $100, but we have always done different amounts.
Ex. Customer brings a check from friend or family member and they have almost enough in their account to cover the check. We would put a one day courtesy hold on the account instead of holding the item longer than need be.
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#2212459 - 04/30/19 04:55 PM
Re: Courtesy Holds
Linkpars
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Power Poster
Joined: Sep 2010
Posts: 2,662
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Yeah, what you call them (probably) doesn't matter as long as you follow Regulation CC. When you say you put a one day hold on, how does that work? Deposit today, released tomorrow? Or, deposit today, held tomorrow, released the next day?
_________________________
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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#2212460 - 04/30/19 04:55 PM
Re: Courtesy Holds
Linkpars
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Power Poster
Joined: Nov 2004
Posts: 6,724
Illinois
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Reg CC as a standard hold (2-5) days. There are no more non-local checks so there is no such thing as a 5 day case-by-case hold any more. You can place a case-by-case hold making funds available no later than the second business day provided that you make $200 available the first business day. The $100 next day requirement was changed by Dodd Frank in 2011. I wonder if your institution's Reg CC procedures need updating.
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#2212468 - 04/30/19 05:43 PM
Re: Courtesy Holds
Linkpars
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100 Club
Joined: Jan 2007
Posts: 179
Kentucky
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Yes we would place the hold today and release tomorrow.
I am aware of the changes through Dodd Frank.
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#2215426 - 06/11/19 06:26 PM
Re: Courtesy Holds
Linkpars
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Platinum Poster
Joined: Nov 2013
Posts: 549
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Yes we would place the hold today and release tomorrow. I realize I'm quite late to the party - but I wanted to follow up on this particular statement. This sounds like a routine, everyday deposit to me. This is the way every single check deposit is handled here - even on-us checks. The deposit is made and the funds become available during nightly processing. If it's a cash deposit the funds are available the moment the transaction is complete at the teller window. Am I missing something here? Is this not standard practice industry wide?
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#2215495 - 06/12/19 12:09 PM
Re: Courtesy Holds
Linkpars
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Platinum Poster
Joined: Jun 2014
Posts: 568
Petersburg, VA
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We have same day availability here. Checks deposited today are available immediately, unless a hold is placed. Linkpars may have the same availability practice.
But yes, I believe most banks make funds from checks available through nightly processing.
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#2215496 - 06/12/19 12:15 PM
Re: Courtesy Holds
Linkpars
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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We're the same as burke 116 - immediate availability unless a hold is placed (which is rare).
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#2218056 - 07/19/19 04:49 PM
Re: Courtesy Holds
Linkpars
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Platinum Poster
Joined: Sep 2005
Posts: 590
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Would you not only hold the amount of the deposit but any other previously available funds to cover that deposit?
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