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#2238159 - 06/16/20 04:23 PM Multiple checks, large deposit hold
MCCompliance Offline
Member
Joined: Nov 2012
Posts: 95
When placing a hold for multiple check types, do you look at each type separately for the hold timing or can they be combined for a large dollar exception hold? Can someone confirm if the scenario below is the correct way to place the hold?

Cashier check for $7750 and personal check for $3250 deposited today.

Available tomorrow $5200 (5000 from cashier check and 200 from personal check)

Available Thursday $3050 (remainder of personal check - case by case hold)

Available next Thursday(6/25) $2750 (remainder of cashier check)

Thank you in advance.
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#2238165 - 06/16/20 05:00 PM Re: Multiple checks, large deposit hold MCCompliance
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,643
They can be combined for a large deposit exception hold. Now, keep in mind that the amounts change on July 1, 2020, but here is what it would be as of today:

$11,000 deposited today.

Exception Hold (for the amount over the first $5,000): $6,000 can be delayed for 7th day availability.
Case-by-case Hold (for the first $5,000 that can't be held under an exception hold): $200 must be next day, but the remaining $4,800 can be delayed for second day availability.
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2238169 - 06/16/20 05:19 PM Re: Multiple checks, large deposit hold MCCompliance
MCCompliance Offline
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Joined: Nov 2012
Posts: 95
If one of those checks is a Cashier Check, would $5,000 need to be available the next day, or are we okay giving the $200 next day and $4800 the 2nd day?
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#2238173 - 06/16/20 06:12 PM Re: Multiple checks, large deposit hold MCCompliance
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,643
Ah, yes. Moving a bit too quickly today. The way I did it above would work for non-next day items. With the next day item over $5,000, you'd have $5,000 available next day.
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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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#2238177 - 06/16/20 06:19 PM Re: Multiple checks, large deposit hold MCCompliance
MCCompliance Offline
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Joined: Nov 2012
Posts: 95
Thank you!!
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#2238234 - 06/17/20 03:18 PM Re: Multiple checks, large deposit hold MCCompliance
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,864
Cape Cod
You get to decide which check is used up first. See Official Interpretation C. 229.13(b)-1.

OPTION #1: If you include the "other" $3250 check and $1750 of the cashier's check in the first $5,000, you'd have $1750 plus $200 available on BD 1 after the day of deposit; $3,050 available on BD2, and $6,000 on BD 7

OPTION #2: If the first $5,000 is $5000 of the cashier's check, you get $5,000 on BD 1 and $6,000 on BD 7.

Of those options, #1 produces the least favorable result for the depositor.
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#2238261 - 06/17/20 05:07 PM Re: Multiple checks, large deposit hold MCCompliance
MCCompliance Offline
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Joined: Nov 2012
Posts: 95
Awesome, thank you!
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