A Case-by-case hold on a local check must be available on the second day. What good is that when we have checks that take up to a week before we know they are coming back? By then the money could be gone. Too late then to put an exception hold on. Someone help me understand what good is putting a hold on a check taken, ie, Monday to be released tuesday night to be available on Wednesday.

This is only one of the problems with Reg. CC. A number of years ago, there was an attempt to change local case by case checks to third day availability, but it didn't happen.

The last statistics that I saw indicated the average return time for a local check was 2.2 days. For a nonlocal check, the average return time was 5.5 days. On two occasions, the Fed went to Congress and asked that they increase the case by case hold periods to 3 and 6 days for local and nonlocal checks respectively.

Congress was clearly unimpressed. Regulation CC is a consumer protection law, it was never intended to assure that the banks got an even break. Accordingly, only the exception holds provide any significant amount of protection.