Answer:
Yes. You would have to provide them a disclosure substantially similar to Model C-1 found in Appendix C in Regulation CC telling customers that you are a next-day bank.
First published on BankersOnline.com 9/17/12
Reg CC Disclosure Required if Do Not Place Holds
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Question:
If a bank does not place holds on deposited items, is a Regulation CC disclosure required since it is not the policy of the bank? This bank sends any questionable check item for collection via mail.
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