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Does Reg CC Apply to A2A or Mobile Deposits?

Question: 
I have a few questions regarding Reg CC: 1. For accounts less than a year old, and a check is over $500, we place it on a 2-day hold, is that allowable under the Reg? 2. For accounts open more than a year and checks more than $3k but less than $5k, we place it on a 2 day hold, is that allowable under the Reg? 3. Does Reg CC apply to A2A deposits or mobile deposits?
Answer: 

by Randy Carey:

I have no idea what a A2A deposit might be, but the availability schedule for mobile deposits would be disclosed in your mobile banking agreement as they are currently not covered under Regulation CC.

Answer: 

by Brian Crow:

A2A likely means "Account to account" which would be an electronic transfer. Although Reg CC requires next day availability for electronic transfers, Reg E and NACHA rules require same day credit.

Remember that if you are the originating bank and are debiting an account at a different bank, the offsetting credit at your bank is an internal entry which would not be covered by Reg CC so you can delay providing the credit by account agreement to give you time to ensure the debit clears the other bank.

Answer: 

by John Burnett

I agree with Brian's interpretation of "A2A."

A hold with availability at the start of the second business day after the banking day of deposit is permitted for any check other than those for which you have to provide next-day availability.

At least for now (until Regulation CC is updated again), mobile-deposited checks are not subject to the availability requirements of the regulation, so you can hold the funds for whatever period you have described in your bank's mobile deposit agreement.

First published on 04/19/2020

Last updated on 4/20/2020

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