Per Reg CC, a banking day is defined as any business day (up to the bank's cut-off hours) when your institution is open for substantially all of its banking activities. Reg CC measures availability of funds in business days. Are we, the bank, allowed any time from open of business to 3:00 pm (our cut off time) to release a hold? Our disclosure goes over the terms Business Day and Banking Day. But under the delay we use Business Day. So should the funds be available the start of business day the hold is removed?
Our bank has several MSB check cashing customers. On occasion, an MSB customer will inadvertently cash an altered check, which eventually is deposited to their account at our bank. When our bank receives an affidavit of alteration from the paying bank, is it permissible to debit the MSB customer's account for the claim amount since they are the ones that "cashed" the check, or would our bank be responsible for paying the alteration claim?
I'm implementing Remote Deposit Services in my bank. Our main and only customer will be a foreign bank. Basically, the foreign bank is my parent company. However, we are independent from them in terms of regulations applicability. The foreign bank is not allowed to open US dollar accounts for their customers. Therefore, the foreign bank will purchase checks from their customers and each will be scanned through RDC. We will receive the images of the checks. My question is: Does regulation CC apply to the foreign bank (which is my customer)?
Our customer is furious because we paid a check on his account that he wrote over eight months ago. He claims that was illegal because the check was stale-dated.
If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?