Has anyone done a Reg CC audit lately? If you have what type of things did you look at. We are a same/next day availability bank. We usually only use case by case holds.

Believe it or not external auditors criticized us for not placing holds. If you've had any losses I would suggest thinking about changing your procedure.

We don't have much loss in that area, there are many banks like ours in our area. Same day, next day availability. Does anyone have any suggestions for auditing?

Here is the FDIC regulation. It will give you a good start!

There a several things to look at. 1. make sure all of you policies, disclosures and practices agree. 2. spend some time with the exception holds verify that they were placed for legitimate purposes and that they were released on time.

At our last exam we got written up for no setting exceptions holds according to our disclosures, we were more leinient. - go figure.

I thought providing less restriction than the regulation was acceptable. I honestly look at every hold the day after it's placed. Regulation CC is difficult and our front line staff 'forgets' that you can't place a 7 day case by case hold on an out of state deposit and sets them up that way. We have trained twice in the last six months and there are still problems. Good luck.

I don't know if this will help your efforts or not - Bankers Tools provides under Reg CC Resources from Jim Bedsole a Reg CC Calculator which I loaded for our tellers use. It's a great resource, plus our tellers print it off and attach to the hold notice as additional documentation.

Could I talk out out of sharing your audit with me.
We too are case by case holds.

Thanks!

Since they have done the updates, this does not clearly show who you are responding too, nor does it notify them unless you PM them.

Private mail me and I will also give you our guidance. Using what you receive might help. Also I do a detailed review on my Reg CC. With the Hold Report ITI produces you can see what has been placed. You could find holds placed that were not documented in the branch files. I then review each hold to the documentation required for Reg CC and our polices. We have had many quarterly reviews were the branches failed, so I look at Reg CC quarterly and more frequently if necessary. I have one branch that cannot place a hold without administrative approval due to their failure rate.

I also review holds daily. WE are a next day availability bank, but do a fair amount of case-by-case, new account and exception holds. At this recent compliance exam we had no exceptions...I believe that was a FIRST!!!

Bear in mind with the Reg CC caluclator, you need to back up your system hold date by one day so it will actually be available on that next morning.

As an aside, the examiner's that complained about the leniency of "shorter than you could do holds" would have gotten one good argument from me!

I also downloaded onto our computers, it is helpful.