I just want to double check. We have been sent a late return claim by a large FI that states we took longer than the 24 hours from presentment. We are 100% check 21 and only deal with images from the FRB. Within the 24 hours there was a holiday and clearly the FI did not take that into consideration. This customer is a check kiter, so I am sure that they are the FI that had "no chair when the music stopped" and are trying what they can do to get it collected, hoping we just give in. Does a letter back to the FI stating the time fact around the return take care of it?

The Fed has procedures that you should follow when disputing a late return allegation. In essence, you provide and document the cash letter information for presentment of the check and do the same for the return item letter. A lot of late return claims are wishful thinking on the part of the depository bank.

Just be sure that the holiday you refer to is one provided for in Regulation CC, and not some locally observed day that doesn't count, if it makes any difference to your case.

Thanks John

Yes, definitely check on that holiday. Not 100% the same thing, but I had a small credit union call me to dispute a dishonored return (untimely). When we painted the picture - after a few attempts - she realized that just because THEY were closed the day after Thanksgiving, did not mean the whole ACH network was.