Answer:
You are always permitted to impose an exception hold under Section 229.13(b) for check deposits over $5,000, assuming, of course, that you make the proper notification. The release schedule you describe is appropriate in such a case.
If a check is labeled in accordance with Section 229.36(e) as "payable through" a bank other than the drawee bank (as is sometimes the case with credit union checks), you base your local/non-local decision on the information in the Section 229.36(e) label, and not on the MICR line. In the scenario which you describe, the check will be MICR-encoded with the payable-through bank's routing number, but labeled under Section 229.36(e) as payable by the local credit union. Base your local/non-local decision on the four-digit routing symbol of the credit union, and consider the check local.
First published on BankersOnline.com 4/4/05
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