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#92416 - 06/27/03 08:02 PM Check holds
Anonymous
Unregistered

My question is with regard to check holds placed on redeposited checks. My Compliance Officer insists that when I place a hold it must be dated from the original date of deposit. If a check was originally deposited on the 9th of the month and comes back to us on the 13th, I feel the hold should be placed the day of the redeposit, and not on the 9th. It seems like we could get stuck since some time has elapsed. Help.

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General Discussion
#92417 - 06/27/03 08:32 PM Re: Check holds
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
See the Commentary Reg CC 229.13(c) last paragraph "to determine when funds must be made available for withdrawal, the banking day on which the check is redeposited is considered to be the day of deposit. Hope this helps.

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#92418 - 06/27/03 09:39 PM Re: Check holds
KK Offline
100 Club
KK
Joined: Jan 2002
Posts: 249
Southern California
Does it make a difference if the hold is placed because of being notified that a check is coming back? Would you go from the date of deposit then?

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#92419 - 06/27/03 10:40 PM Re: Check holds
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
KK,
No, it does not make a difference. Reg CC always calculates the hold period from the banking day of deposit.

Readers: Please note, I am not disagreeing with ComplyLady. Platform Queen is asking about a redeposited check. KK is asking about a different exception hold, reasonable cause to doubt collectibility.
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