New Account Hold

Posted By: LSmith

New Account Hold - 08/01/17 03:02 PM

Reg CC states: An account is not considered a new account if each customer on the account has had, within 30 calendar days before the account is established, another account at the depositary bank for at least 30 calendar days.

Our scenario. New business opens new business account. Authorized signers have had deposit accounts personally open since 2014.

Can we invoke the New Account Hold rule or not?
Posted By: Elwood P. Dowd

Re: New Account Hold - 08/01/17 03:08 PM

The "business," partnership, corporation, sole proprietorship, what?
Posted By: LSmith

Re: New Account Hold - 08/01/17 06:30 PM

The New business account is a Limited Liability Company
Posted By: John Burnett

Re: New Account Hold - 08/02/17 06:54 PM

The customer is the LLC and the LLC doesn’t have a transaction account that’s been open for 30 days or more. The LLC’s new account is a new account for purposes of the regulation.