Skip to content
GeoDataVision
Learn More - Click Here!

Thread Options
#2265577 - 02/01/22 05:18 PM Reg CC and Fraud
Anonymous Offline
100 Club
Joined: Jun 2021
Posts: 181
If we have a customer that deposits a check into their checking account that we suspect might be fraudulent, can we place a hold on it? if so, what type of hold would it be? Reason to doubt collectability?

Return to Top
#2265606 - 02/01/22 09:46 PM Re: Reg CC and Fraud Anonymous
SmallBankBSA Offline
100 Club
Joined: May 2018
Posts: 173
"reason to doubt collectability" should only be used if you have reason to believe the check will not be paid.
did you contact the paying bank to verify funds or anything about the check? Based on what you're saying you "think" it will not be paid.
Is it a new account? have they had over drafts? is it a large dollar check?

Return to Top
#2265615 - 02/02/22 02:16 PM Re: Reg CC and Fraud Anonymous
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,630
dmk124, why do you suspect the check might be fraudulent?

As SmallBankBSA said, you need to have good reason to believe the check won't be paid. Specifically, Regulation CC says that if you are going to use the "reasonable cause to doubt collectability" special exception hold, you must have "facts that would cause a well-grounded belief in the mind of a reasonable person." In addition, Regulation CC says that "such belief shall not be based on the fact that the check is of a particular class or is deposited by a particular class of persons."
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2266286 - 02/14/22 04:44 PM Re: Reg CC and Fraud Anonymous
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Check their overdraft history, that's the most frequent extended hold reason we place.

Return to Top
#2266493 - 02/16/22 09:29 PM Re: Reg CC and Fraud Anonymous
RVFlyboy Offline
Power Poster
RVFlyboy
Joined: Oct 2000
Posts: 5,980
Soaring over Georgia
If you suspect the check may be fraudulent, you can always refuse to accept it for deposit and offer to send it for collection instead. Then you don't have to worry about Reg CC and if the check is fraudulent, it won't be able to be successfully collected.
_________________________
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions

Return to Top
#2274084 - 08/12/22 04:12 PM Re: Reg CC and Fraud Anonymous
KarenK Offline
New Poster
Joined: May 2011
Posts: 17
PA
Are there any exceptions to Reg CC hold time frames for fraud? At times the longest hold period is still too short of a time frame.

Return to Top
#2274086 - 08/12/22 04:43 PM Re: Reg CC and Fraud Anonymous
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
Describe the fraud you are talking about. If you suspect fraud, you refuse the deposit.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2274089 - 08/12/22 05:35 PM Re: Reg CC and Fraud Anonymous
KarenK Offline
New Poster
Joined: May 2011
Posts: 17
PA
depositing a check into an account where the person may have deposited other fraudulent checks. I also suggested to just not take the check, that wasn't received very well. IE: Customer service aspect.

Return to Top
#2274090 - 08/12/22 05:46 PM Re: Reg CC and Fraud Anonymous
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
You have an individual that you believe is depositing fraudulent checks and someone is worried about a customer service issue? That someone has a screw loose. Close the account and be done with it or otherwise you are stuck with either Reg. CC, sending the check for collection, or refusing the deposit.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2274098 - 08/12/22 07:35 PM Re: Reg CC and Fraud Anonymous
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,424
Florida
"Dear Branch Manager, it's your choice to keep the account open, but if any check comes back as fraudulent, the amount will be reimbursed to the bank from your end of year bonus."

Bet the mindset changes
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2274161 - 08/15/22 05:47 PM Re: Reg CC and Fraud Anonymous
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,535
Pulling people out of the ditc...
we already have the in place, Rocky, but it impacts the entire branch's quarterly incentive, puts the onus on all associates, not just the manager. this certainly makes everyone more vigilant and a lot less likely to scream "but they're a good customer"!
_________________________
Providing alternative truths since the invention of time

Return to Top
#2274191 - 08/15/22 08:24 PM Re: Reg CC and Fraud Anonymous
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,424
Florida
{{ Like }}

A major Bank in FL in the mid 90's did a relationship analysis, ranking the profitability of clients. The top 10% of the profitable customers produced over 75% of the income for the bank. The bottom 1/3rd accounts all lost money. They started a "rank and yank" program. Profits increased every quarter as the lower accounts went to other banks.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2274446 - 08/19/22 03:09 PM Re: Reg CC and Fraud rlcarey
KarenK Offline
New Poster
Joined: May 2011
Posts: 17
PA
I think I will suggest the collections aspect. rlcarey, Loved your comment though
!

Return to Top

Moderator:  Lestie G