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Reg CC Hold for Excessive NSF Fees

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What are some specific reasons for a Reg CC hold? Could the number of NSF fees on an account be a reason?

The only specific reasons are listed in Section 229.13 (the exception holds):

  • New account (Section 229.13(a)) - checks deposited to an account that qualifies as a "new account" under Section 229.13(a)(2).
  • Large deposits (Section 229.13(b)) - checks totaling over $5,000 were deposited to the account or accounts on one business day.
  • Redeposited checks (Section 229.13(c)) - one or more checks that were earlier deposited but returned unpaid for overdraft or insufficient funds is being deposited.
  • Repeated overdrafts (Section 229.13(d)) - Any check is deposited to an account of a customer who has been repeatedly overdrawn (as defined in this section).
  • Reasonable cause to doubt collectibility (Section 229.13(e)), as explained in this section.
  • Emergency conditions related to check collection (Section 229.13(f)), as explained in this section.

The repeated overdrafts exception comes the closest to what you asked about, but note that it is not directly related to the fees assessed on the account.

The so-called "case by case" hold, which can delay availability to the second business day (and is therefore not often used any longer) can be imposed for any reason or no reason at all.

First published on 5/23/11

First published on 05/23/2011

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Filed under compliance as: 

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