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Opening New Business Account (Reg CC Guidelines)

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Question: 
I have two customers, Harry and Larry, that have had checking accounts with our bank for more than 30 business days prior to opening a new business account titled xxxxxx LLC. Would this be considered a new account per Reg CC guidelines since the business has not had any accounts with our bank?
Answer: 

XXX LLC is a new customer; the exception hold, properly disclosed, would be available to you.

If Harry or Larry opened a new account the hold would not be available. If they had described this hold accurately, it would have been the "new customer" not the "new account" exception hold.

First published on 07/22/2018

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