Is anybody willing to share how they apply Regulation CC to nonconsumer (business accounts)? We are a former thrift - now a community savings bank - just entering into business/commercial deposit relationships, and at present our application of Reg CC is the same for consumer and nonconsumer accounts. However, our business relationship manager advises that most commercial depositors will find the 'extended hold' provisions - especially the 'Large Deposit' float extensions - to be onerous and 'out of sync' with the rest of the banking industry.

I'm looking for some 'practical' guidance...

Your present application of Reg. CC in the same way to both consumer and business accounts is correct. Reg. CC makes no distinctions between consumer and commercial accounts.

I always tell our assoicates that the exceptions holds should be utilized when you are uncomfortable with the check or the customer relationship. For example, it is not a requirement to use the Large Deposit Exception when a deposit includes a large check. You are free to place a CBC hold instead (or no hold). I don't know of too many community banks that place holds across the board for everything coming over the counter. Our opertions officers use their discretion when placing holds. It all comes down to "knowing your customer."

Dolly Nugent
Vice President
Compliance/CRA Officer
Citizens Business Bank

As a follow-on to Ken's comment -- Although Reg CC covers both household and business accounts, there is nothing (in the regulation) that prevents a bank from having different availability policies for business and household accounts. And there are some very limited differences in what you can do with business accounts as far as notices are concerns. I know of some banks that provide general next day availability to business accounts and some level of delayed availability to consumer accounts. (we're not one of these banks.)