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#2260782 - 10/06/21 01:29 PM Reg CC Hold - Can you change the reason?
mnbanker09 Offline
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Joined: Jan 2018
Posts: 128
A customer presented a check for deposit for about $3k. (This customer had a deposited item that had been returned NSF, different maker.) When this $3,000 check was accepted for deposit, the teller placed a case-by-case hold. The next business day after deposit, we contacted the payee bank and they shared that the check will not be paid. Can we send an updated exception hold notice?

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Deposits and Payments
#2260794 - 10/06/21 02:46 PM Re: Reg CC Hold - Can you change the reason? mnbanker09
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Yes. You now have new information leading you to a reasonable belief the check will bounce, so you can change the CBC hold to an exception hold based on that reasonable belief. Be certain to notify your customer with the appropriate notice. Given the fact that you first told the depositor the CBC hold would be released by the morning of the second business day after the banking day of deposit, and that would be today or tomorrow, I'd also suggest a phone call to give the depositor a "heads up."

Annotate your retained copy of the exception hold notice with the info about the call to the paying bank, which provided the basis for the extended hold.
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John S. Burnett
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#2260798 - 10/06/21 02:57 PM Re: Reg CC Hold - Can you change the reason? John Burnett
mnbanker09 Offline
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Joined: Jan 2018
Posts: 128
Thank you!

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#2260805 - 10/06/21 03:11 PM Re: Reg CC Hold - Can you change the reason? mnbanker09
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Remember that the deposit date doesn't change, so the funds will be available by the morning of the 7th business day after the banking day of deposit unless you extend it under wording of the last sentence in 229.13(h) and comment 13(h)-4.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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