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#800911 - 08/23/07 01:04 PM Credit card checks
TXBSA Offline
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Joined: May 2006
Posts: 170
TX
Are credit card checks subject to the same rules as regular checks under Reg CC? What is the availability schedule on these?

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#800917 - 08/23/07 01:11 PM Re: Credit card checks TXBSA
John Burnett Online
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John Burnett
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Posts: 39,873
Cape Cod
Yes, they are subject to the same rules as "regular" checks. There are no special Regulation CC rules for credit card checks.
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#800955 - 08/23/07 01:49 PM Re: Credit card checks John Burnett
LaNae Offline
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Joined: Apr 2002
Posts: 36
Upper Midwest
I know that we had problems with those types of checks being returned to us in the past and our old compliance person had us put exception holds on all credit cards checks. Needless to say when the OCC came for an exam we had a problem.

If the customer is someone you wouldn't hold a "regular" check for, then don't put a hold on. If it's a customer who has been a repeat overdraft customer for example then put an exception hold with that reason, again only if you would hold a "regular" check.

Just be certain that you treat credit card checks the same as any other check to avoid any possible violations of Regulation CC. I know that the length of the hold may not prevent the bank from taking a loss should the check come back but Reg CC was designed to protect the consumer and not the bank.

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#800965 - 08/23/07 02:02 PM Re: Credit card checks LaNae
John Burnett Online
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John Burnett
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Cape Cod
And if you have doubts about the check, but can't legitimately place a hold on it, you have every right to refuse it for deposit.
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John S. Burnett
BankersOnline.com
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#801170 - 08/23/07 04:34 PM Re: Credit card checks John Burnett
Milby Offline
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Joined: Apr 2007
Posts: 953
Tejas
I have found the >$5,000 rule has been fairly useful for credit card checks - a large number of checks we receive are for large amounts. Also, a 5 day case-by-case hold has helped many of our customers avoid overdrafts when their card checks have been returned unpaid for whatever reason.

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