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#2223633 - 10/11/19 04:11 PM Reg CC Hold Notice - 'Amount Held'
mnbanker09 Offline
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Joined: Jan 2018
Posts: 123
The bank's general policy is to make funds available on the next business day. In review of Reg CC Holds, I'm finding that the 'Amount Held' stated on a hold notice is the full amount of the deposit, even when $200 or more of funds are available the next business day.

I believe the 'Amount Held' on a hold notice should only state the amount that is delayed beyond our regular availability schedule (Next Day). Is this an acceptable practice have the 'Amount Held' match the Deposit Amount? Thanks in advance.

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#2223634 - 10/11/19 04:40 PM Re: Reg CC Hold Notice - 'Amount Held' mnbanker09
rlcarey Online
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Joined: Jul 2001
Posts: 80,393
Galveston, TX
(2) Notice at time of case-by-case delay--

((i) In general. When a depositary bank extends the time when funds will be available for withdrawal on a case-by-case basis, it must provide the depositor with a written notice. The notice shall include the following information--

(A) A number or code, which need not exceed four digits, that identifies the customer’s account.

(B) The date of the deposit;

(C) The amount of the deposit that is being delayed; and

(D) The day the funds will be available for withdrawal.
The opinions expressed here should not be construed to be those of my employer:

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#2223783 - 10/16/19 03:29 PM Re: Reg CC Hold Notice - 'Amount Held' mnbanker09
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,876
Cape Cod
Some bankers have interpreted item (C) in Randy's list as requiring the full amount of the deposit, part of which is being delayed. However, that reading isn't supported when you consider the purpose of the notice. You should be informing the depositor of how the hold affects availability of his deposit. And that means disclosing the amount being delayed. Item (C) would have been more clearly worded in the regulation as "The amount from your deposit(s) that is being delayed." Or even more simply, "The amount that is being delayed."
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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