Maximum hold times

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Question:

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.

Answer:

The large deposit hold delays the excess over the first $5,000 in checks to the seventh business day (except for any on-us checks, which would only be delayed to the second business day), but the bank is allowed to “order” the checks in any way it wishes. You want the first $5,000 to include all non-next-day checks first. If you haven’t reached $5,000 yet, include any on-us checks. Then and only then, include next-day items like Treasury checks, official bank checks, state and local government checks, etc.
Then, go back to that first $5,000 in checks. Make the first $200 available on the first business day after the banking day of deposit and the rest you can put a second-day availability on.

NOTE: Regulation CC availability minimums are changing on July 1, 2020, and banks must have completed their implementation of those new minimums by that date. Once a bank has made those changes, the dollar amounts in my response will change from $5,000 to $5,525 and from $200 to $225. Banks can use greater amounts than those, and would adjust their calculations accordingly.
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