What’s the combination of large deposit and case-by-case holds we can use to delay availability as long as possible of as much of a mixed-check deposit that includes next-day checks and other checks as possible? We want to delay the customer’s use of as much of the deposit as possible for as long as possible, within the “safe harbor” holds limits. The deposit is made in person to a bank employee to an account held by a payee of all the checks.
If I am an employer, may I use the paid sick leave mandated under the Emergency Paid Sick Leave Act (EPSLA) to satisfy paid leave entitlements that an employee may have under my paid leave policy?
May a Trust open a safety deposit box?
Are banks able to accept checks for deposit or cashing that have no payee written on the payee line? What is the risk behind accepting these checks?
How soon must my bank eliminate the transfer limits on its savings accounts?
How does integrating our LOS to an imaging system increase the value of our LOS?
We have seen customers commit fraud by using remote deposit capture to deposit the same check at multiple banks, by using the same image of the check front but different check backs in order to use multiple restrictive endorsements. Under Reg CC or the UCC, what is the best way to argue against another bank that their claim is legitimate and ours isn’t? Both banks have an image with their restrictive endorsement, and theoretically the captures could have been made within a short amount of time. How can we defend ourselves from being left holding the bag?
If a customer has in IRA Certificate of Deposit and makes withdrawals within six days of one another, is this a Reg D violation unless a minimum seven day interest penalty is assessed? Is there different treatment if the customer is more or less than 59 1/2?
Prior responses on this site are somewhat contradictory:
Q&A - "Limit of Distributions on IRA accounts" and "IRA Client CD Deposit-Exception to Penalty (Reg D)" both answered by Randy Carey.
In the first he states "Any withdrawals within six days of one another would require an automatic seven day interest penalty under Reg D." There is no differentiation based on age in the response.
In the second he states "Any withdrawal from an IRA is exempt once the person reaches 59 1/2"."
Which really applies?
Does UDAAP apply to just consumers, or all customers?
What, exactly, did the Federal Reserve Board change in Regulation D that affects savings accounts?