If any of the customers on the new account has NOT has a transaction account with you for the last 30 days, you may consider the account a new account.
However, if all of the customers on the account have had another transaction account with you for the last month (singly or jointly), you may not consider the account "new" for purposes of section 229.13(a).
Sam, Sarah and Josie are opening a new joint account. Sam and Sarah have another joint account with the bank, and Josie has her own account with you. You cannot use the new account exception hold on this new joint account.
Harry and Sally are opening a new joint account. Sally has another account with you, but Harry is new to the area and banks elsewhere. You can use the new account exception hold on the new joint account.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8