To add to what the others have said, I agree that you can't use the "reasonable cause" hold exception just because you weren't able to verify funds at another institution. If this person did get facts that would justify the hold reason, I agree with you that the description is not sufficient. In fact, it sounds to me like your team (or at least this person who placed this hold) probably needs additional training on this.
As far as a citation, the commentary isn't the most direct on the particular scenario of not being able to verify funds, but I think its clear enough that you would need factual information from the paying bank to lead you to the conclusion that a check won't be paid.
From the commentary as an example of when you can use the "reasonable cause" hold:
"b. The depositary bank may have received information from the paying bank, prior to the presentment of the check, that gives the bank reasonable cause to believe that the check is uncollectible. For example, the paying bank may have indicated that payment has been stopped on the check, or that the drawer's account does not currently have sufficient funds to honor the check. Such information may provide sufficient basis to invoke this exception. In these cases, the depositary bank could invoke the exception and disclose as the reason the exception is being invoked the fact that information from the paying bank indicates that the check may not be paid."
In addition, another part of the commentary says this:
"4. The regulation provides that the determination that a check is uncollectible shall not be based on a class of checks or persons. For example, a depositary bank cannot invoke this exception simply because the check is drawn on a paying bank in a rural area and the depositary bank knows it will not have the opportunity to learn of nonpayment of that check before funds must be made available under the availability schedules. Similarly, a depositary bank cannot invoke the reasonable cause exception based on the race or national origin of the depositor."
The bottom line is that not being able to verify with the paying bank whether a check is good or not, is not a fact that would give "reasonable cause to believe that the check is uncollectible."
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com