We have international customers who maintain an FX (Hong Kong dollar) account with us. The customer notified us that they wish to deposit funds and then wires the deposit to our Nostro account in Hong Kong. Once we are notified by the HK bank that they receive the deposit, which can be up to 3 days, we credit them the funds into the customer’s account.

My question is does Reg. “CC” apply to this transaction? If it does, should we start counting the availability days from the date the Hong Kong bank received the funds on our behalf, or the day we are notified of the receipt of the funds?

thank you in advance,

Paul

What is the source of the deposit and is this considered a transaction account on your call report as defined by Regulation CC and Regulation D?

We do not book the funds until we are notified of the receipt.by the Nostro Bank that they received it. At which point it would show in the customer's DDA.

Thanks,


Paul