We have a customer that conducted a mobile deposit of a check. We are placing a hold on the check for reason to doubt collectability because the check is stale dated. The customer was scammed and already withdrew a large sum of money. Are we able to place a hold on her account yet for the full amount of the check, which would put her at a negative balance because she already withdrew the funds?

Since mobile deposits are not covered under Regulation CC, you can do anything that your mobile deposit agreement says you can.

if she has already withdrawn the funds, what good does placing a hold do? i'm a bit perplexed, but perhaps i've misunderstood what you wrote.

I think they were trying to prevent releasing any future deposits. Under Regulation CC, nothing would prevent you from placing a hold on account after the fact that exceeds the current balance in the account. But it sounds like the horse is already out of the barn.

Correct. She's made a few deposits so we're basically preventing future deposits being released for when/if this check gets returned.