It is my understanding that we do not need to complete an Exception Hold notice under 12 CFR 229.13(g) if we are holding funds based on the New Account exception. Our Funds Availability Disclosure is provided to the customer at account opening and is disclosed under the ("Special Rules for New Accounts" section), so the thought by the Regulators is (apparently) an additional specific hold notice is not required.

My question is, would we need to complete a hold form if said customer comes in two weeks later to make a deposit?

A new account hold during the first 30 days does not require a notice if you have it in your availability policy.

Those of us more seasoned compliance geeks who were around when Reg CC sputtered to life about 34 years ago remember that bankers argued while the rule was still a proposal that customers should be able to remember something they were told a month earlier.

"More seasoned" - ha - love it John. I am probably considered "well seasoned" at this point.

When I was on an ABA team in 1992 reviewing the Fed's proposed Truth in Savings Act regulation (Regulation DD), I remember we used the same argument about consumers remembering the disclosures for a time deposit with a term of a year or less (or would be able to find the disclosure in their records), so that full disclosures wouldn't be required when the deposits were approaching maturity and automatic rollover.

Of course, the argument doesn't admit the fact that many (most?) consumers toss out most of banks' disclosure paperwork and don't pay attention to those disclosures when their accounts are opened.