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Reg CC and Debit Card Deposits

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Under Reg CC, how are deposits made by debit card treated? (These might be a deposit at an ATM or a merchant refund on a debit card burchase, as examples.) Can we hold these for three days even for existing customers?

Deposits at proprietary ATMs must be provided the same availability schedule as deposits made at a teller window with the exception of next-day items that aren't US Treasury or on-us checks which can be treated as local checks if not deposited in person.

Deposits at non-proprietary ATMs can be held up to the 5th business day provided that your Funds Availability Disclosure states this along with how customers can distinguish between proprietary and non-proprietary ATMs.

Debit card refunds are electronic funds transfers and must be credited the day you receive them to comply with Regulation E and Visa/Mastercard Operating Rules.

First published on 04/21/2024

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