My understanding is that this a repository for institutions to report counterfeit checks, forgeries, etc. The hold reason would simply be "information received from the drawee bank indicates that the check will not be paid." Once upon a time BOL used to publish "Alerts and Counterfeits" for institutions that reported counterfeit cashier's checks. Of the three prudential regulators, I think the OCC is the only one that still requires the regulator be notified.
Trying to keep up with all of those manual notices would be impossible for a teller, but if we placed a hold based on those old Alert and Counterfeit notices, the reason would be the same. We wouldn't reference an OCC bulletin, we'd simply say the drawee indicates the check may not be paid.
A Reg CC notice is not like an FCRA adverse action notice that requires we disclose information obtained from a third party.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com