Answer:
by Jim Bedsole:
Your answer is in Section 229.13(a) of Reg CC. The large dollar exception applies to the aggregate amount of deposits by one or more checks on any one banking day. In your scenario, the first $5,000 of the total deposit would need to be made available on the next business day, but the remaining $15,000 can be held under the large deposit exception hold until the 7th business day.
Answer:
by Brian Crow:
If your policy allows it and the new customer has not had a transaction account within the last 30 days, the remaining $15,000 could also be held up to the ninth business day using a new account exception hold under 229.13(a)(1)(ii).
Answer:
by Jim Bedsole:
And for further clarity, if any of the other exception hold reasons also apply, you could hold the first $5,000 until the seventh business day as well. For example, if the customer is a frequent overdrafter (as defined by Reg CC), or you have reasonable cause to doubt the collectibility of the checks, you could also hold the first $5,000.
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