Is there a hold reason "Your account did not have sufficient funds to cover the item(s) at the time the deposit was made"? I don't see it in any of my training manuals, but it's on our hold notice. If so, does the first $100 need to be made available? Say in the case of a $5000 non-local check.

It sounds like reasonable cause to doubt collectibility, which falls under an exception hold, thus no $100 requirement.

Kansayaku-

But there's no info that doubts the collectability of the items that were deposited. For all anyone knows, the items itself is fine. It's the account being credited that is in question.

Just a thought.

I agree with the Swedish Chef. Just because your depositer doesn't have money in their account, doesn't mean that the check they are depositing is not good.

Thanks guys, but have you ever heard of a hold being placed for this reason. It's an actual selection on our hold notice. I'm not sure why the vendor that we get these notices from would put it on there if it's not an actual reason. Although, I agree that it's more and acct suspicion than an item suspicion.

Thanks for noticing my error. I misread the question. (See what only five hours of sleep in the past two days gets a compliance person. )

I am pretty sure there are only 6 reasons for an exception hold: 1. large deposit, 2. redeposited checks, 3. repeatedly overdrawn, 4. reasonable cause, 5. emergency conditions, and 6. new account. These can be found under Reg CC Sec 229.13.

Oops, I forgot to log in. That anonymous was me.

Dottie- you might want to check with your vendor to see why it was printed on there. Maybe it was midquidedly requested by a long gone employee years ago? Maybe the vendor has a good reason.

But I haven't read anything about being able to put an exception hold for 'you have no money in your account so we're holding these funds longer' holds. I see the logic but then being that restrictive on accounts, you're gonna get people not wanting to deposit money.

You could do a Case by Case hold and then you don't need a reason...but your expirations are much shorter. My advice is to follow the Reg's definitions. During an exam, I don't think the response of, "Well, it's on the form" will fly. Although it would be fun to use. . It's like saying, "We've always done it this way!" haha.

Thank Swedish Chef. I will take your advice.

I love that answer:

"We've always done it this way!"

I hear that more times than not. It's so amazing why people do things. You ask them to explain and that's their reason. Then you show them the legalities and they say:

"We've always done it this way!"

To which you say, change is good!