REG CC Amendment Changes

If a NEW customer deposits a check that is now in the "other check" (the new local/nonlocal combo) category, what is the maximum number of days a hold can be placed on that item? In the past we would have placed a 10 day hold but I am uncertain now with the new amedment. I have seen some examples with 9 days and some with even 11. Also, What is the maximum number of days ANY type of item can be held under the new amendment rules(excluding emergency condition reasons)?

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Reg CC does not put a limit on the number of days you can hold an "other check" when it's deposited into a new account. That is set by bank policy. Ours is 11.

The maximum umber of days you can hold a check is 7 days, with the exception of new account holds. For new account holds, next-day items (the amount over $5,000) can be held for 9 days and other checks can be held as long as your policy allows.

Are you taking under the new account exception? There are no maximum timeframes under the new account exception and it would only be limited b the timeframe in your disclosure.

If you are talking under one of the other exceptions - the maximum would be 7 business days (large item exception - only amounts over $5,000)

Otherwise it is 2 business days.

There was no change to anything other than Appendix A, so the new account rules have not changed. The lack of any non-local checks means that exception holds other than the new account hold must provide availability by the 7th business day. The emergency conditions hold is an exception, of course, as is a hold for which the bank can justify a longer duration than to the 7th business day (see last sentence in §229.13).

As for the new account hold-

• cash and electronic credits must be available on the first business day or sooner
• traveler's checks are considered next-day items
• the first $5,000 of next day items must be available on the first business day
• the balance, if any, of the next day items must be available by the ninth business day.
• Funds from other checks (other than next-day items), including on-us checks, can be made available by the Nth business day, where N is a number you include in your account disclosures. There is no limit on N in the regulation, but consider that 20 or 21 business days comprise a calendar month, and the new account status only endures for 30 calendar days. For that reason, I don't think that N should be larger than 20, and most bankers I've talked with are using 11 - 15.

Thank you all so much!! That is just what I needed.