Does it matter if you use a Case-by-case hold or Exception hold on a new account?

Use a new account hold, if you have differentiated one in your new account disclosures.

We don't have a hold notice specifically for new accounts...do we have to??

If you don't have new account hold available to you, then I don't believe that you can use that as a reason for the hold - but I think I'd like to see on of our moderators weigh in on this. You would have to find a reason under your case-by-case, or exception hold notice - problem with not having a new account hold available to you, is that the other holds may not give enough time for the item to be processed.

You probably don't have a hold notice for new deposit holds because a notice for this reason is not actually required under Reg CC.

We just finished a Fed exam and the lead examiner who reviewed our exception hold notice form suggested that we add a box to our exception hold notice form for the new account hold. We do disclose the new account hold in our initial funds availability policy and we do provide an exception notice more for operational reasons than consumer. Our operations department reviews holds placed on accounts and the form is used so they will know why.