The $400 rule requires that you have a processing system capable of incrementing up availability at 5 p.m.
Let's say you have a non-local check of $1,000 deposited on Monday. You have to make $100 available for withdrawal on Tuesday, and the balance of the check should be made available for withdrawal on Monday of the following week (five business days). If you use the $400 rule, you can prevent your depositor from withdrawing CASH from that $900 on the fifth day (Monday) until 5 p.m. At 5 p.m., you have to free up cash access of $400, and the remaining $500 must be available for cash withdrawal by the opening of business (or 9 a.m. at latest) on Tuesday.
That only applies to cash access. So it could prevent ATM withdrawals, check certification, teller withdrawals, POS authorizations. At 4 p.m., the balances against which ATM and POS transactions are authorized would have to be refreshed with the newly-available $400. And all day long on Monday, any inclearing checks would have to be paid against that $900 (remember, it only affects cash access).
The wrinkle was a "bone" that got thrown to bankers who argued that cash access on day 2 or 5 would expose them to too much check fraud risk.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8