I have an existing customer who has a checking account. Today she opens a new savings account. The check she has is from a settlement company and for a large amount. She wants to put some of it into her existing checking account and the majority into the new savings account. She has had a few overdrafts but not excessive. What type of holds can I put on either of the accounts?
Can I put two different holds on one check? A new account hold on the savings? An exception hold on the part that went into checking?

Unless your state mandates that your funds availability be extended to savings accounts, remember that Reg CC only applies to transaction accounts (e.g. you can put as long of a hold on the savings account as you wish.)

Also review your funds availability policy to see if it applies to "transaction accounts" or "all deposit accounts." If your policy extends to savings accounts, then you obligated yourself to provide more protections than Reg CC requires.

In either case, remember that Reg CC defines a new account as an account opened in the last 30 days when the customer has not had a transaction account for at least 30 days. If your customer had opened a new checking account, a new account hold would not be an option because they are an existing customer.

Since it doesn't sound like you have any reasonable cause to doubt collectability, your option for the amount deposited to the checking account is a case-by-case hold combined with a large item hold (assuming the amount deposited to the checking exceeds $5,000).

Thank you so much Brian. You're always my life line. I appreciate your help.