Anonymous #2 is correct, you can use the reasonably cause exception hold and you do have to provide the notice. Under reasons, you can use the statement "We have confidential information that indicates the check may not be paid" on the customer's notice. However, on the bank's copy of the notice (which you are required to retain), you must note the specific information that led to this hold, such as "we had evidence that the customer is kiting." Simply having the confidential information statement on the bank's copy of the notice is not enough.
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Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions