Hoping someone will help clear my fogged up brain.....have a customer who made a large dollar deposit in the ATM on a new account. Early next morning, did an online transfer to another account using some of those funds before we could process a new account hold on the item. Does Reg CC allow us to hold those funds that was transferred to the other account also or will the hold only apply to the account the item was deposited to? Thanks in advance for the help!

The answer depends on whether you include the languge from Appendix C-7 in your funds availability disclosure.

C-7—Holds on Other Funds (Other Account)

If we accept for deposit a check that is drawn on another bank, we may make funds from the deposit available for withdrawal immediately but delay your availability to withdraw a corresponding amount of funds that you have on deposit in another account with us. The funds in the other account would then not be available for withdrawal until the time periods that are described elsewhere in this disclosure for the type of check that you deposited.