Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#67537 - 03/13/03 10:22 PM Notice for when funds are considered deposited
Anonymous
Unregistered

Is there a requirement to post cut-off times at teller lines? I can't find it in Reg CC. Does anyone know what Reg this would be addressed in?

Return to Top
Operations Compliance
#67538 - 03/14/03 02:00 PM Re: Notice for when funds are considered deposited
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
I know of no actual regulatory requirement to post the cut-off time at the teller line, but most banks that have one do in order to avoid customer confusion.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#67539 - 03/14/03 05:30 PM Re: Notice for when funds are considered deposited
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
We do post, mostly as a matter of customer service.
_________________________
The opinions expressed are mine and do not necessarily reflect those of my employer.

Return to Top
#67540 - 03/14/03 05:42 PM Re: Notice for when funds are considered deposited
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Our Wal-Mart facilities close at 7:00 during the week, but hte cut-off time is 6:00. We post this along with signs stating that Saturday deposits aren't credited until the following business day.
_________________________
My Opinions Only

Return to Top
#67541 - 03/15/03 03:41 AM Re: Notice for when funds are considered deposited
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,752
On the Net
Jeeze, if this is what you want, I feel dirty using a Reg. CC answer. We have it at the teller lines, and I believe have used this cite as justification, OSC and the timing cite.

§229.16 [Commentary] Specific Availability Policy Disclosure 6. The business day cut-off time used by the bank must be disclosed and if some locations have different cut-off times the bank must note this in the disclosure and state the earliest time that might apply. A bank need not list all of the different cut-off times that might apply. If a bank does not have a cut-off time prior to its closing time, the bank need not disclose a cut-off time.

§229.16 (c)(2)(ii) Timing of notice. The notice shall be provided to the depositor at the time of the deposit, unless the deposit is not made in person to an employee...
Last edited by Andy Z; 03/15/03 03:57 AM.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#67542 - 03/17/03 02:08 PM Re: Notice for when funds are considered deposited
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
Andy,

Doesn't 229.16(c)(ii) just talk about the timing requirements for the delivery of a case by case hold notice. Although the cut-off times are required to be in the intitial disclosure, I really don't think there is a requirement in Reg CC to post cut-off times at the teller counter.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#67543 - 03/17/03 02:39 PM Re: Notice for when funds are considered deposited
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
I agree, Reg CC refers to notifying the customer in the disclosures. It does not require you to physically post the cut off time in the lobbies or elsewhere.

Return to Top
#67544 - 03/25/03 04:34 PM Re: Notice for when funds are considered deposited *DELETED*
Kansayaku Offline
Diamond Poster
Joined: Jan 2003
Posts: 1,454
metsuretsu
Post deleted by kansayaku
_________________________
I have many opinions; some are good, some are bad, and some don't contradict.

Return to Top
#67545 - 03/25/03 05:07 PM Re: Notice for when funds are considered deposited
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
This references the time periods available for withdrawal, not the cut off time.

Return to Top
#67546 - 03/26/03 03:17 PM Re: Notice for when funds are considered deposited *DELETED*
Kansayaku Offline
Diamond Poster
Joined: Jan 2003
Posts: 1,454
metsuretsu
Post deleted by kansayaku
_________________________
I have many opinions; some are good, some are bad, and some don't contradict.

Return to Top
#67547 - 03/26/03 07:17 PM Re: Notice for when funds are considered deposited
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
See the Appendix C C-15 and C-15A. These are the disclosures to be posted where consumer deposits are accepted. They do not reference cut off times. The bank's various cut off times are generally provided to the depositors at time of acct opening.

Return to Top
#67548 - 03/26/03 07:27 PM Re: Notice for when funds are considered deposited
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I think the reference should be to samples C-17 and C-18.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#67549 - 03/26/03 07:40 PM Re: Notice for when funds are considered deposited
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
C-15 and C-15A refer to disclosures where consumer deposits are accepted, C-17 and C-18 are disclosures for ATM's and deposit slips (but maybe my book is old and the #'s are wrong, but the descriptions of the notices should be the same) THe original question was referring to disclosures where deposits are accepted.

Return to Top
#67550 - 03/26/03 07:48 PM Re: Notice for when funds are considered deposited
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
One last thought on this issue. I don't think anyone is advocating "not" posting cut-off times at the teller line. It's just that it is not a regulatory requirement. I have always suggested that it be posted as a customer service.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#67551 - 03/26/03 09:02 PM Re: Notice for when funds are considered deposited
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
I agree, however management usually disagrees. And as it is not required, it is not posted. The reason I would like it is not for Reg CC, but for the customers who think there deposit will be posted that day, but it is after cut off so it is not posted until the next day.

Return to Top
#67552 - 03/26/03 09:40 PM Re: Notice for when funds are considered deposited
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
I think your management may have lost sight of who signs their paycheck if they balk at fully informing your customers of your policies.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#67553 - 03/26/03 09:46 PM Re: Notice for when funds are considered deposited
1111 Offline
Platinum Poster
1111
Joined: Jan 2003
Posts: 580
Quote:

Our Wal-Mart facilities close at 7:00 during the week, but hte cut-off time is 6:00. We post this along with signs stating that Saturday deposits aren't credited until the following business day.




Speaking of Wal Mart, did you know that they closed all the Wal Marts in Baghdad? They re-opened as Targets!

Return to Top
#67554 - 03/27/03 02:34 PM Re: Notice for when funds are considered deposited
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
The cutoff times for the braches, ATM's, and night depositories are included in the documents provided to the deposit at time of acct opening so they are fully informed. That is what is required, at least here in Florida.

Return to Top

Moderator:  Andy_Z, John Burnett