I agree John, but I've always felt the regulation was written backwards on this one. In practical application, core systems want to know how many business days to hold funds in order to calculate availability, so its not a surprise that the industry calls it a two-day hold rather than second day availability. I'm hopeful (but not expectant) that the next revision of Reg CC may address this in one way or another to make the rule align with practical application in the world of holds.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com