Our bank received information from our bank system provider suggesting we should be including the "Bounce" availability to our call reporting figures to the Federal Reserve. They state that due to a recent reg interpretation the information is required to be reported as "unused funds."

I don't remember reading anything about this in the new Reg DD changes regarding ODP. Did anyone else read this and where did they find it?

One place you will find it is in the FRB's SR05-3/CA 05-2 dated 02/23/05, last paragraph bottom of page 4 and top of page 5.

It can also be found in the Federal Agencies Joint Guidance on Overdraft Protection Programs, dated 2-18-05, page 8.

I believe it depends on who your regulator is...OTS differs from the other regulators I believe in respect to how they should be reported (OTS does not consider it credit for that respect). Not sure if you will find it in the text, but here are the websites you can check...

http://www.ots.treas.gov/docs/r.cfm?73252.pdf

http://www.occ.treas.gov/occ_current.htm (scroll to 4/6/05 for link to issuance)

Thank you both. Our regulator is FDIC.

It's also in the Call Report instructions for Schedule RC-L as updated March 2005.