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Placing Hold After Initial Deposit

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Question: 
Can we place a hold on an account two days after the initial deposit has been made due to information received after the fact?
Answer: 

If you are asking about an exception hold, yes. However, be careful. The funds availability for the hold will still have to be determined by referring to the date of the deposit, not the date you received the negative information. If the funds have to be made available on the seventh business day from the day of deposit, and two of those days have already passed, the length of the hold has to be shorter to make the funds available on the correct day. Don't forget the special provision concerning the payment of overdrafts and waiver of fees requirements in Regulation CC's Section 229.13(e)(2) if the exception hold is being placed because of a reasonable doubt that the check will be collected.

First published on BankersOnline.com 5/30/11

First published on 05/30/2011

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