One of the items required to be stated on the Reg CC hold notice on a reasonable cause to doubt collectability exception hold is the date of deposit. If the hold is being placed a day or two later, due to a notification from the Fed about the check being returned, wouldn’t we still use the date of deposit on the hold notice, and not the date of the notice?
Based on my understanding of the situation, I believe you would use the date of deposit, not the date of the notice. But also, wouldn’t you also have the option to charge it back and suspend the funds, pending the actual returned item?