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#1593112 - 08/17/11 06:51 PM New Account Holds
Rosebud123 Offline
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Joined: Oct 2003
Posts: 645
Florida
If a have lets say an eleven day hold for all new accounts. Do I need to give a hold notice at the time of deposit?

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Operations Compliance
#1593518 - 08/18/11 02:59 PM Re: New Account Holds Rosebud123
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
There is not a notice requirement for a new account exception. Some banks have a practice of giving notice for info purposes, but it's not required for that specific exception hold.
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#1593549 - 08/18/11 03:31 PM Re: New Account Holds Rosebud123
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Look at the wording in your disclosure. If you say you "will" put on the XX day hold (as the model does) you are not required to give a notice. If you say you "may" put on the XX day hold, you need to provide a written notice at the time the deposit is made.
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#1593716 - 08/18/11 05:33 PM Re: New Account Holds Elwood P. Dowd
Rosebud123 Offline
Platinum Poster
Joined: Oct 2003
Posts: 645
Florida
Oh. It says will. So it should be ok not to give it. Great information thank you.

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#1593742 - 08/18/11 05:52 PM Re: New Account Holds Rosebud123
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
That also means that in most cases you apply the new account hold period disclosed. Your disclosure must reflect what you do in most cases.
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