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Has anyone lowered their exception day holds to four, as proposed in the reg but not implemented? I am at a new bank that places holds more than occasionally. They don’t like placing exception holds for 7 days. I want to revise our Funds Availability Disclosure and was thinking of lowering the extended hold time frame to four days. With the faster electronic settlement, we really haven’t had any issues with longer check returns or late return notifications.
I could leave it at 7 days in the policy to be safe put only hold for 4 days; however I was afraid an examiner would say it isn’t really our “policy” to hold for 7 days.
During our last exam the examiner listed, under recommendations, the Funds Availability Policy needed to match our practice. Our practice was same day and our policy was next day, so we changed our policy and notice to match our practice. This was to the customers benefit but it was still listed as a recommendation. We normally see returns by the 3rd or 4th day, but we have received fraudulent money orders on the 8th day. I would suggest making your policy and practice/procedures match which ever you choose.
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