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New Accounts & Notice Of Delayed Availability

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Question: 
Do we have to complete a Reg CC, Notice of Delayed Availability form when opening a new account for a customer? My former bank did not, and my current compliance officer thinks we should be.
Answer: 

12 CFR Section 229.13 [Commentary] Exceptions
a. If a depositary bank invokes any of the safeguard exceptions to the schedules listed above, other than the new account or emergency conditions exception, and extends the hold on a deposit beyond the time periods permitted in Section Section 229.10(c) and 229.12, it must provide a notice to its customer.

I believe the thought process is that you have just delivered the new account hold disclosure when the account was just opened and no additional exception notice is required.

This may not be the opinion of my employer and should not be relied upon as legal advice.

First published on BankersOnline.com 06/2/03

First published on 06/02/2003

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