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Reg CC Hold-One Large Exception Hold?

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Question: 
This pertains to a Reg CC Hold. I have a check for $25,475.00 drawn on a closed retirement account issued from the retirement bank to the customer. For a large deposit exception would I make $200 available next day, $4,800 available the 2nd business day and the remaining $20,475 available on the 7th business day after the deposit, correct? Is this considered one large deposit exception hold or two separate holds, the first being a case-by-case and the second being the large deposit, or should I make the first $5,000 available the next day and the remainder available on the 7th business day?
Answer: 

First, you have to know whether the check is a cashier's check or teller's check. In this case, you have said the check was issued from the retirement bank, and I'm not certain what that tells us. If it's a check drawn on the bank that issued it, it's a cashier's check and will be a next-day availability item. That would mean you cannot place a "case-by-case" hold.

If that is true, and using the new Regulation CC availability requirements, the first $5,525 would be available on the first business day after the banking day of deposit, and a large deposit hold on the remaining funds would make $19.950 available on the 7th business day.

If, on the other hand, the check is not a next day item (issued, perhaps by an insurance company that held the retirement account), you could use a combination of a case-by-case hold and a large deposit hold to make the first $225 available on business day one after the banking day of deposit, $5,300 available on business day two, and the balance of the check available on business day seven.

Of course, you can make the funds available sooner than either of those options requires, depending on your policies and your assessment of the risk involved in accepting the check for deposit.

First published on 08/09/2020

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