Well, you don't need to use CBC holds to hold funds to the second day. Suppose that your customer deposits an $800 check on Monday. You have to provide the first $225 by Tuesday morning whether you use CBC holds or not. You can delay the availability of the rest of the check until Wednesday morning without a CBC hold if your disclosed routine practice is to delay availability to the second business day. So technically, the CBC hold question doesn't affect the requirement to make that first $225 available.

But if, as I suspect, it is your disclosed routine practice to make funds from deposited checks available the business day after the banking day of deposit, except when you impose an exception hold, then I would agree that mention of the $200 current and the $225 starting July 1, next day availability isn't required.

Maybe I missed it. I can't find guidance on what to do about customers who do not get mailed statements. Is a link on the Bank's Home page compliant? Or do we have to sort out those who do not get a statement mailed, and do a separate mailing? If that has been discussed, I sure missed it.

I assume you are delivering the statements electronically? You are not able to add statement messages to your electronic statements?

OK, so I have not had my coffee yet. I don't know what I was thinking. Thanks rlcarey.