10 Day Hold on Check?’
09/19/2021
I am wondering if it is against regulations to place a 10-day hold on a check? I always thought we couldn't go past 9 days. Please refresh my memory!
Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.
Mr. Crow has been, and continues to be, an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.
Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud.
See all Upcoming and On-Demand training presented by Brian.
You can contract Brian at b_crow@tcaregs.com.
09/19/2021
I am wondering if it is against regulations to place a 10-day hold on a check? I always thought we couldn't go past 9 days. Please refresh my memory!
09/12/2021
Since MasterCard’s Zero Liability covers ATM withdrawals and PIN transactions. It is even worth investigating Reg E claims since we are always on the hook?
09/12/2021
Can we require a copy of a customer’s receipt if they are disputing the amount of a charge?
08/01/2021
If a cardholder who is under contract with a merchant and that merchant feels that they are still entitled to those funds, can they force through a charge on a closed or hot-carded debit card?
08/01/2021
How long do we need to keep debit card dispute docs? (What is the time of retention?)
08/01/2021
We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.
07/25/2021
During a review of the account, we noticed several transactions to Cash App, to the same people from last December and one in January. These were NOT disputed. Should we inquire about these transactions? If so, could we start our calculation from the statement date (plus 60 days) from the statement with the first unauthorized transaction? Does it make a difference that the December, the May and June transactions were on different cards? (The customer has had multiple cards.)
07/25/2021
I have a question about telephone transfers. The telephone transfers we perform are for the customer who calls the bank and requests the teller to withdraw from one account and transfer funds to another account. We currently have a custom form that a customer signs to perform ongoing telephone transfers and we keep this on file authorizing the bank to perform these transactions. We would like to discontinue using this form. Is this old form necessary and is it even a compliance requirement under Electronic Fund Transfer Act? We currently document on the transaction ticket "Telephone Transfer per Customer request". Any advice or information would be greatly appreciated.
07/25/2021
Can a customer initiate an ACH Return for unauthorized debit from a closed bank account?
07/25/2021
I have a commercial customer who had her signature forged on payroll checks in her January statement. Can these items be sent to the BOFD for collection now that we are in early May?