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Change-Of-Terms Notice for New Reg CC $200 Rule

Answered by: 
Randy Carey

Question: 
With the new $200 rule for Reg CC, since our Bank has a next-day availability policy, our general policy is not affected. But on the case-by-case holds, if I understand it correctly, we will now have to make the first $200 available on the next business day. If I am right up to this point, do we need to send out a change-of-terms notice to our customers about the change for the case-by-case holds only?
Answer: 

You need to reveiw your current Funds Availability Policy disclosure that you give to your customers. If you mention the $100 availability in the disclosures (which would be dependent on the specific model disclosure form that you are using) then a change of terms notice will be required to change that portion of the disclosure to reflect $200.

First published on BankersOnline.com 7/25/11

First published on 07/25/2011

Filed under: 
Compliance
Filed under compliance as: 
Availability
Disclosures
IT

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