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.

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.

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?

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?

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).

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.

Thanks Randy, much appreciated!

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.