What Exception Holds Must Use the $200 Rule?

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Question:

There seems to be some confusion with regard to the first $200 rule under Reg CC among some people who I've spoken with. Does it apply to exception holds placed for "doubtful collectability" or "redeposited checks"? What exception holds must use the $200 rule?

Answer:

Brian (6/4/2012)—The requirement to make $200 available the first business day after deposit found in Section 229.10(c)(vii) applies to case by case holds and the bank's general funds availability policy if it has chosen to place blanket holds on all check deposits.

This $200 requirement does not apply to any of the exception hold reasons found in Section 229.13. The full amount of a check may be held for all exception hold reasons with the exception of the large item exception which requires that the first $5,000 be made available according to the bank's normal availability schedule.

The large item exception also may be used in conjunction with a case by case hold making $200 available on the next business day, $4,800 available on the second business day, and the remainder by the seventh business day.

First published on BankersOnline.com 6/4/12

Answer:

John (7/14/2021)—UPDATE: Nine years have passed since Brian responded to this question. Regulation CC was amended effective July 1, 2020 (and will be adjusted July 1, 2025, and every five years thereafter) to make inflation adjustment to several of the dollar amounts in the regulation. See revised section 229.11 for the current and historical amounts.

In the 2020 adjustments, the $200 amount mentioned by Brian was changed to $225, and the $5,000 amount for large deposit holds was increased to $5,525. The $5,525 amount also applies to the new account hold on "next-day" deposited checks and to the criteria for considering a depositor a repeat overdrafter.