Regulation CC - Hold Periods

Background Info. - Our bank implemented a calendar for the branch offices to utilize when placing holds on deposited checks for regular holds and extended holds.

Example #1: The calendar indicates that Non-Local items are "available 6th day after the day of deposit."
Question: Shouldn't this be made available no later than the 5th business day after the day of deposit, in accordance with Reg CC?

Example #2: The extended hold calendar indicates that local items are "available on the 7th business day after the day of deposit."
Question: Shouldn't this be made available no later than the 5th business day after the day of deposit, in accordance with Reg CC?

Example #3:
The extended hold calendar indicates that non-local items are "available 12th business day after the day of deposit."
Question: Shouldn't this be made available no later than the 11th business day after the day of deposit, in accordance with Reg CC?

updated

The REG CC Information in the Bankers Toolbox is very helpful. As is the Hold Notice Calendar 2007 to calculate a correct release date for the hold.

That calendar will be updated in the next couple of weeks too, by the way. If any one want first crack and helping me double check it, please send an email to andyz@bankersonline.com and in teh subject, put "Reg CC calendar proofing." Thanks.

Thanks for everyone's feedback. It is helpful to have other professionals offer their expertise with the daily issues affecting the banking compliance world. I will be discussing this issue with operations management again either today or tomorrow.

Can anyone explain when case-by-case holds can be used? If a bank discloses an availability schedule which is sometimes in line with Reg CC (eg. wires and US Treas checks) and sometimes better for the customer (eg. non-local checks 2nd day after deposit)can the bank still use case-by-case holds or only exception holds?

Please confirm - do your disclosures tell the customer non-local checks will be available after 2 days?