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Disclosing Same Day Availability

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We disclose that we give same-day availability for cash and wire transfers because the funds are available to the customer if they come into the bank, but they are not available through the debit/ATM card network because we only send a positive balance file after we do our nightly update. Are we out of compliance by disclosing same day availability for these deposits?

You are not required to make cash and wire transfer deposits available on a same-day basis by Reg CC. However, your current disclosure is inaccurate because it doesn't accurately reflect your practice. I suggest that you add a disclaimer indicating "next business day availability for ATM and Debit card access".

First published on 7/23/07

First published on 07/23/2007

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