I've done some searching but can't find a definite answer. Our hold policy states to place exception holds on 'third party credit card checks.' Allowable or not?

Probably not. Reg CC says you can't make a blanket hold policy for a class of checks, which is the way this sounds. However, if you have specific information that a check is doubtful, you could maybe use the Reason To Doubt Collectibility on a case-by-case basis (but you have to have specific information pertaining to THAT check.) It may be easier to revise the policy to say that type of check will be sent for collection rather than taken for deposit.

I say no. Credit Card checks themselves have their share of questionability, but I have researched this myself and find they fall under Reg CC. An as stated you may not define a class of checks.

The FDIC consumer compliance examiners are very clear on this issue. Using credit card checks as a reason to place a hold will get you written up for a violation of Reg cc. It is a class of checks and this is not a good reason to place a hold.

(And guess who taught some of them to be that way...... Although I can't take credit for ALL of them.)

Aren't we allowed to put case by case holds on anything we want without a reason?

Yes, in general. Perhaps my choice of wording was poor, I was not referring to case by case holds but infrequent, well considered exception holds. Sorry about that.

Whew! Thanks.