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During our last FDIC exam, they recommended we update our Reg CC Funds Availability Policy. Our policy says next day availability but our practice is same day availability. Has anyone else had examiners address this issue? If yes where did you get sample language for same day availability?
Appendix C to Regulation CC contains Model Availability Policy Disclosures. There is no model form for same-day availability. You may want to ask the examiner for a source of the information that he/she sent you in search of. I suggest modifying an existing form, such as the next day availability form, to make it work in your situation. In doing so stick as closely as possible to the existing model language.
Add I encourage any other users of the Forum to respond if you have had a similar experience.
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