Our bank is researching the possibility of invoking the Reg CC New Account Hold for all new accounts. We have been doing this on a case-by-case basis. However, we are looking at automating the process. I was wanting to know how many of you out there actually invoke the New Account Hold for all or most of the New Accounts for the first 30 days after opening? Also, do you do this across the board for all new accounts or on a case-by-case basis? I don't want to have any CRA issues by not being fair if we automate the process. I am in Texas and I don't believe that many banks actually do this especially since Check 21. Any comments will be appreciated. Thanks.

We do if they the account is their first deposit relationship with the bank.

Thus, if they already have a savings, and then opened a checking account, we would not consider that checking as new since we feelt hey have proven themselves.

From all the banks that I have visited in Texas (a lot), it is not a common practice. It is a case-by-case issue.

I think Bank of America automatically places holds on all new accounts.

All of the banks I have worked at place new account holds on all non-next-day availability items. I believe being consistent across the board in this manner will actually reduce the possibility of unfairness (read: discrimination) that could result from applying new account holds on a case-by-case basis.

Also, BBS's bank's practice is also an option but not required. You may treat an accountholder as new even if they had a prior savings account since a savings/MMDA or CD is not considered a transaction account.

We only due case by case. Actually, in 13 yrs I've never worked for an institution that has an automatic new account hold for the first 30 days. I have "heard" larger institutions are doing this but have not experienced it first hand. I know some of the internet based banks have "automatic" holds on ALL deposits. Still trying to figure that one out.

Most banks leave this to the discretion of the branch. If you are going to do it across the board, then consider for "walk-in" customers only. For existing customers and those that are brought in by business development officers, holds could be placed on a case-by-case basis.

I agree with some of the other posters. The big banks do this. People move their accounts from big banks to get away from this kind of treatment. Do you want to put your bank in the same category with the big banks?