Description
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WHAT?
The Expedited Funds Availability Act (EFA Act) and its implementing Regulation CC (12 CFR 229), as amended, was enacted in August 1987 and became effective in September 1988. The regulation sets forth the requirements that depositary institutions make funds deposited into transaction accounts available according to specific time schedules and that they disclose their funds availability policies to customers. Additionally, Regulation CC was updated with availability changes effective July 21, 2011, and most recently, July 1, 2020.
Regulation CC is both a consumer protection regulation as well as a safety and soundness regulation. How does a depositary institution balance the competing factors of protecting the customer and protecting the bank at the same time? Also, how does the depositary institution ensure it maintains compliance with this regulation so as to prevent consumer harm?
WHY?
This recording provides a review of what is acceptable under Regulation CC when the institution is presented with items to either be cashed or deposited into an account with the institution. Upon completion of this recording you’ll understand:
- The definitions in the regulation and how they apply to various situations related to holds and availability of funds;
- The availability of funds, by timeliness and amount;
- The changes as of July 1, 2020;
- The disclosure requirements at account opening, where deposits are received, and when holds are placed on deposits;
- When a hold can be placed on a deposit;
- How to deal with various deposit scenarios; and
- How to ensure compliance through regular monitoring.
TOPICS
The recording covers:
- Regulation CC specific terms;
- Availability of Funds, including Case-by-Case, Exception and Piggy-Back Holds;
- Changes effective July 1, 2020 and what financial institutions should consider;
- Policy and Disclosure Requirements;
- Scenario Discussion; and
- Monitoring Techniques.
WHO?
This recording is designed for compliance officers, retail management, training personnel, auditors and anyone else with responsibilities related to the accepting deposits into a transaction account in compliance with Regulation CC.
PRESENTER
Scott Carr, CRCM, CRMA, CAFP is the Executive Vice President and Chief Risk Officer at First Savings Bank headquartered in Jeffersonville, Indiana. His main responsibilities include managing the overall enterprise risk function for the organization; establishing and monitoring operating benchmarks, developing and reviewing methodologies to minimize overall risk and maintain the reporting structure established for measuring and managing the risk function. Scott has his bachelor’s degree in Business Finance through Indiana University Southeast; he completed the LSU Graduate School of Banking, and admirably served in the United States Navy. Scott is a CRCM (Certified Regulatory Compliance Manager) from the ABA; a CAFP (Certified AML and Fraud Professional) from the ABA; and has a CRMA (Certification in Risk Management Assurance) from the Institute of Internal Auditors.
