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#2252341 - 04/14/21 01:14 PM Reg CC - Availability of Funds
Compliance1 Offline
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Can some of you explain how your core systems work when it comes to holds on accounts? So, for a 2 day hold, are your systems designed to have the hold drop off after the first business day so that the funds are available on the second business day? Or do your systems keep the hold on for two full business days and then your systems drop the hold off?

Our operations department has some documentation that states to hold the item for 2 days but the regulation says funds are to be made available the 2nd business day after the day of deposit.

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#2252345 - 04/14/21 01:55 PM Re: Reg CC - Availability of Funds Compliance1
Skittles Offline
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TN
For the two day hold it counts the day of deposit and the next business day. Customers are required to have access to the funds by 9:00 am on the second business day after deposit (i.e. hold on Monday holds the funds Monday and Tuesday - customer to have access by 9:00 am on Wednesday). I've seen some systems that drop the hold off the night before during processing - and others that drop the hold in the morning. You need to find out when your system releases the funds.
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#2252671 - 04/20/21 04:04 PM Re: Reg CC - Availability of Funds Compliance1
Compliance1 Offline
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Thanks Skittles for that explanation.

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#2252690 - 04/20/21 06:11 PM Re: Reg CC - Availability of Funds Compliance1
John Burnett Offline
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It is unfortunate that the industry has come to call this a "two-day hold," when it's more accurate to say a "hold until the second (business) day (after the banking day of deposit)."
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#2252692 - 04/20/21 06:43 PM Re: Reg CC - Availability of Funds Compliance1
Adam Witmer Offline
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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.
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#2252706 - 04/20/21 09:19 PM Re: Reg CC - Availability of Funds Compliance1
John Burnett Offline
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John Burnett
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Cape Cod
I've given up hope on a "next revision" of Reg CC other than the quintennial inflation adjustment.
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