New accounts - we are struggling with the last line of the Reg CC disclosure rule on New accounts.
The model disclosures gives us this language"Funds from all other check deposits will be available on the (number) business day after the day of your deposit."
What are our options for (number) - i can't find any commentary on this. is it TWO? Nine?

There are no limitations for delaying availability for deposits of local, nonlocal and 'on-us' checks in new accounts. However, I do believe you have to be reasonable. Our funds availability policy states that we may hold these no longer than 30 days. I don't think we've ever held them that long, but it allows us the leeway.

ok, i have found in the commentary on 229.13 this explanation on new accounts where it looks like we can use about any number we want as Doug said: "2. Rules Applicable to New Accounts.

a. During the new account exception period, the schedules for local and nonlocal checks do not apply, and, unlike the other exceptions provided in this section, the regulation provides no maximum time frames within which the proceeds of these deposits must be made available for withdrawal. Maximum times within which funds must be available for withdrawal during the new account period are provided, however, for certain other deposits. Deposits received by cash and electronic payments must be made available for withdrawal in accordance with §229.10."

So, now we are struggling with what number to use

Rather than having our management struggle, I strongly suggested the 30 days, since no one could recall holding anything longer than that time period and the didn't HAVE to hold it that long. So it gave them flexibility to call their own shots within the 30 days.

Just remember that unsupportable hold periods were the genesis of the law and regulation. Thirty business days is a month and a half. The customer will have been out of new status for two weeks if the only deposit held is one made the day the account was opened. Twenty business days is roughly one month, and certainly allows plenty of time for any deposited item to come back.