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#2282647 - 03/24/23 04:43 PM Canadian Check Hold
ToddO Offline
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Joined: Aug 2020
Posts: 21
Is there a way to place a hold on Canadian checks that or in US funds. Currently it looks like that would be violating the hold rule due to placing it on an "entire class".

We have seen an uptick in collection issues with Canadian banks and we are trying to mitigate our exposer on checks being deposited into our accounts.

Any suggestions would be great.
Last edited by ToddO; 03/24/23 05:06 PM.
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Operations Compliance
#2282649 - 03/24/23 04:51 PM Re: Canadian Check Hold ToddO
rlcarey Offline
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rlcarey
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Posts: 83,336
Galveston, TX
They are not governed under Regulation CC. If someone wants to deposit a foreign check, the bank can just tell them under what conditions you will allow it. Up to them at that point to continue or walk away.
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#2282651 - 03/24/23 05:10 PM Re: Canadian Check Hold ToddO
ToddO Offline
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Joined: Aug 2020
Posts: 21
Thanks, didn't realize that the Canadian checks do not fall under Reg CC. Would we have to disclose anything to our customers ahead of time telling them that we are changing our process?

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#2282653 - 03/24/23 05:19 PM Re: Canadian Check Hold ToddO
rlcarey Offline
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rlcarey
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Posts: 83,336
Galveston, TX
I am not sure why you would need to. It is a transaction-by-transaction decision as to whether to even accept a foreign check for deposit, I would think. This will probably also only impact what, about .01% of your customers?
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#2283434 - 04/14/23 08:41 PM Re: Canadian Check Hold ToddO
burkemi Offline
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Joined: Nov 2013
Posts: 549
I would like to follow up on this and confirm something, please.

These checks are excluded from Reg CC coverage even if the checks are payable in US dollars, correct? (Check is held by a Canadian bank, but funds are payable in US dollars).
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#2283439 - 04/16/23 12:55 PM Re: Canadian Check Hold ToddO
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,336
Galveston, TX
As long as it is a true foreign bank, the currency denomination has nothing to do with it. Some Canadien banks have accounts in domestic US banks from which they draw checks however. Make sure the check does not have a US routing number.
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#2283455 - 04/17/23 03:50 PM Re: Canadian Check Hold ToddO
burkemi Offline
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Joined: Nov 2013
Posts: 549
Thanks Randy, much appreciated!
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#2283459 - 04/17/23 05:28 PM Re: Canadian Check Hold ToddO
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
U.S. branches and agencies of foreign banks are included in the definition of "bank," so U.S. dollar checks drawn on them will be covered.
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