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#2212429 - 04/30/19 03:51 PM Courtesy Holds
Linkpars Offline
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Kentucky
Just curious if anyone does Courtesy Holds?

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Operations Compliance
#2212431 - 04/30/19 03:54 PM Re: Courtesy Holds Linkpars
BrianC Offline
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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
Linkpars Offline
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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
Adam Witmer Offline
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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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#2212442 - 04/30/19 04:14 PM Re: Courtesy Holds Linkpars
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We do case by cash holds all of the time. Although with the large increase in fraud lately in my area, we are utilizing exception holds a lot more frequently now.

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#2212446 - 04/30/19 04:24 PM Re: Courtesy Holds Linkpars
HappyGilmore Offline
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Pulling people out of the ditc...
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
Linkpars Offline
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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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#2212451 - 04/30/19 04:39 PM Re: Courtesy Holds Linkpars
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As previously stated, all of the time, and it depends on the check and customer relationship. Customers don't like holds and we would never call them a courtesy hold like Happy said.

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#2212452 - 04/30/19 04:40 PM Re: Courtesy Holds Linkpars
Adam Witmer Offline
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Case-by-case holds are very common and used frequently by other institutions.
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#2212453 - 04/30/19 04:41 PM Re: Courtesy Holds Linkpars
Skittles Offline
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TN
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
Adam Witmer Offline
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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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#2212456 - 04/30/19 04:50 PM Re: Courtesy Holds Linkpars
Linkpars Offline
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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
Adam Witmer Offline
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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?
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#2212460 - 04/30/19 04:55 PM Re: Courtesy Holds Linkpars
BrianC Offline
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Quote:
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
Linkpars Offline
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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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#2212469 - 04/30/19 05:43 PM Re: Courtesy Holds Linkpars
P*Q Offline

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Because of the recent Reg CC changes, during our last FRB compliance exam in the late Fall, one of the focus areas was Reg CC and holds and notices (where they never had been historically in the past based on my experience) so I agree with Brian, make sure your procedures are up to date and ensure holds are being applied consistently and in accordance with Reg CC.

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#2215426 - 06/11/19 06:26 PM Re: Courtesy Holds Linkpars
burkemi Offline
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Originally Posted By Linkpars
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
burke116 Offline
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RVA
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
Skittles Offline
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TN
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
Skyline Offline
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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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