How is everyone handling "holds" for mobile deposits? I know they are not covered in Reg CC and we don't really specifically address them anywhere in our policy or procedures.

You should address what your policy will be on mobile deposits in your mobile deposit agreement. You can choose what you want your policy to be and there are no limitations such as in Reg CC. But keep in mind, Reg CC came about because lenders were haphazard in their application of check deposit holds and in many cases were holding items far longer than appropriate for the risk exposure. We brought Reg CC on ourselves and if we aren't careful, we will wind up with regulatory mandates on availability of mobile deposits.

Our policy is really vague and trying to decide if we should keep it that way. The only reason we would look to place a hold on a mobile deposit if there was reason to doubt collectability.

we look at a number of things - past history, account activity, frequency of deposits (we do have both a daily and monthly limit for $ deposited), length account opened, and also scan via a 3rd party service in determining if a hold is placed or not.

You can put a statement that you will delay availability of funds at your discretion. But do you have a general policy on how long you delay those funds when you put a hold on a mobile deposit? If so, you should put that in. If not, you'll need to make some sort of statement that the length of delay may vary.

From Jim Bedsol's first post, "But keep in mind, Reg CC came about because lenders were haphazard in their application of check deposit holds and in many cases were holding items far longer than appropriate for the risk exposure. We brought Reg CC on ourselves and if we aren't careful, we will wind up with regulatory mandates on availability of mobile deposits."

Background - One of the stories I heard relating to CC was a newly elected congressman from Texas opened an account in a S&L when he first got to Washington. Some 30 days later, he sent an assistant to get cash from the account (pre ATM's), and they came back with NO money as the funds were still "being held". He was livid (appropriately) and unfortunately had an assignment on the Banking and Finance Committee. That's when the poop hit the fan.

The Mobile Deposit disclosure for my personal bank account indicates that any deposits made prior to 10 PM ET on a business day will be available the next day. After 10PM or non-business days will be considered made on the next business day. I can pay a fee for immediate availability.