FORUM PROFILE

Reg CC Large Deposit Hold

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  • #190718
    TheBank
    Participant

    For a large local check deposit, where the excess of $5,525 is held using the large deposit exception hold, and the first $225 is made available the next day, what type of hold complies with Reg CC for the $5,300 portion? We must make the $5,300 portion available the second day after the deposit date, but what should be disclosed as the reason for that portion of the hold, case by case, or large deposit?

    #197154
    kboatwright
    Participant

    For case-by-case – regulations indicate:
    •Must include this option in Funds Availability Policy to use.
    •May be used for any reason (hold amount under $5,525 for large deposit hold,)
    •Must make first $225 of checks deposited available next business day ($225 total – not per check)
    •Place CASE-BY-CASE HOLD for all but $225 of checks deposited for 2 business days.

    For large deposit – that would be the reason you are doing it. But from a UDAP perspective you would need a good reason that wasn’t unfair to the customer. These holds have been cited as UDAP issues for some FIs. Without clear policy and understanding for placing the hold.

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    • This reply was modified 2 weeks, 2 days ago by kboatwright.
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