Reg CC: Restricting Access To The First $100

Yes. Assuming the account in question is subject to your Reg CC funds availability policy, it is possible that one of the safeguardexceptions, other than "new accounts" would apply. Under Regulation CC section 229.10(c), the first 100 dollars must be available the next day for all checks not otherwise required under section 229.10 to be available by that time. However, section 229.10(c) does not apply to the "safeguard exceptions" under 229.13(b) to (f). These safeguard exceptions coversituations involving large deposits, redeposited checks, reasonable cause to doubt collectibility, or emergency conditions. If you have included these exceptions in your funds availability policy and choose to rely on one of the exceptions for a particular deposit, the first $100 of the deposit does not need to be made available on the next business day.