Reg CC

Posted By: Anonymous

Reg CC - 10/25/10 04:56 PM

After reviewing our Funds Availability Policy, I discovered that it encompasses savings and MMDA's. Our hold forms state it doesn't apply to savings or MMDA's. Our state law only includes demand accounts. We are considering amending the policy to include only demand accounts. How would this affect customers who have been given the "old" policy? Would we have to send out the revised policy to all of our customers? I believe it would be easier to amend our hold form to include the savings/MMDA's, train the tellers to apply the Funds Availability Policy to savings/MMDA's, and leave the policy alone. We have our compliance committee meeting coming up and would like any info or comments to help in this discussion. Thank you.
Posted By: Bob The Banker

Re: Reg CC - 10/25/10 05:06 PM

Although this would be the least work, it limits the ability of your bank to hold deposits in savings accounts, weakening your security.

I feel the best long term solution is to put the work in to alter the policy -- it provides better security and freedom of business practice.
Posted By: Anonymous

Re: Reg CC - 10/25/10 06:27 PM

Would we need to send notice to all of our customers if we change the policy?
Posted By: John Burnett

Re: Reg CC - 10/26/10 12:09 PM

You'd need to notify customers who would be affected -- those with savings and MMDA accounts.