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Violations of Reg CC Exception Hold Policy

Question: 
We place exception holds for large deposits. Some of our branches are only allowing the first $5000 that might include a special check that is under $5000. There is some confusion, can you help us determine if we are violating Reg CC exception hold policy? Example #1 A large deposit consists of a special check for $2100 and several local checks totaling $6300.00, total days deposit $8400.00. The special check $2100 is made available the next business day, $2900.00 of the local check is made available in two business days and the remaining $3400.00 of local check is made available in seven business days. Example #2 A large deposit consists of a special check for $2100.00 and several local checks totaling $6300.00, total days deposit $8400.00. The special check for $2100 is made available the next business day, $100.00 of local check is made available next business day, $4900 of local check is available in two business days and the remaining $1300.00of the local check in seven business days. Can you clarify which example complies with the regulation?
Answer: 

Answer by Randy Carey: Assuming by special check you mean one that is automatically subject to next-day availability, neither example is correct and it would be this one:

The special check $2100 is made available the next business day, $100 of the local check is made available the next day, $2800.00 of the local check is made available in two business days and the remaining $3400.00 of local check is made available in seven business days.

Also, be aware that the $100 next day availability is moving to $200 on 7/21/11.

Answer: 

Answer by John Burnett: Actually, your second example complies with the regulation because it provides earlier availability than required by the regulation. The regulation establishes the limits for holds; if you stay within those limits, you're OK.

First published on BankersOnline.com 6/13/11

First published on 06/13/2011

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