04/16/2012
Foreign check deposited to account on 02-13-12 with no endorsement. Deposit made by third party. Now, customer requests wire transfer on 02-14-12. Can we place exception hold for missing endorsement or uncollected funds? We know we can place case by case. Can we place hold on entire deposit amount?
03/26/2012
We have a difference in opinion amongst management in our Operations Department concerning Reg CC Holds and new accounts. The Reg states that if all account owners have "had, within 30 calendar days before the account is established another account at the depositary bank for at least 30 calendar days" the account will not be considered a new account. The problem is with the definition of "account" under Reg CC. Some read the Reg and think we should waive all new account holds for existing customers with any type of account (Checking, NOW, Savings, CDs, and IRA CDs). Some think that we should waive new account holds on existing customers who have transaction accounts (excluding CDs and IRA CDs). Which is correct? Also, let's say a customer has been with the bank for 2 years and has a checking account with a balance of $30K. He deposits a check into a new money market for $250K. Would we be non-compliant of the Reg if we placed a new account hold on the $250K deposit? Technically the money market account is not new because the customer has an existing account but the new account deposit is so much more than what the customer currently has. What if that $250K check comes back?
03/19/2012
Our lending department is looking to start an advertising campaign targeting Jumbo Mortgage Products. They are wanting to offer a special rate for these loans but only target potential customers living in 1 city out of the 8 total that we service. We are just wondering if this will violate any Fair Lending Laws, or could be seen as unfair lending practices.
04/04/2011
If someone else brings in a Cashiers check for deposit into a checking account in the amount of $7000 for another individual, then it would be a 2 day hold? Correct? Would I follow the exception guidelines? First $5000 available in two days and remaining in 7?
03/21/2011
Does Reg CC apply to Canadian Postal Money Orders? We have a customer wishing to deposit a Canadian Postal Money Order and are trying to determine how long we are able to place a hold on these funds.
01/31/2011
If a non-customer requests to cash a cashier's check, issued by our bank, are we required to honor their request or are we allowed to set our own limits in terms of the maximum dollar amount of any item we cash for non-customers, including official checks?
12/06/2010
Can a hold be placed on a postal money order?
11/08/2010
If we place a hold today on the deposit made today, then until that deposit actually posts to the master computer system (say midnight), then we are actually holding funds in the account that are available to the customer, and he can't use his ATM/Debit card in the evening when he goes to the grocery store. Is there anything in the Reg that covers this problem?
10/25/2010
Our bank's availability policy is to make all checks available the day after the deposit. We use a case by case hold to extend the hold to two days. Can you tell me if the decision to place a case by case hold can be placed by an officer after the customer leaves the bank? Our auditor believes that we must get specific information on the check if we do not provide the hold notice at the time of the deposit. She insists that the person who accepts the deposit place the hold. We mail the notice out the same day as the deposit is made, and I understand that we cannot charge OD fees if we do not place the hold at the time of the deposit.
10/04/2010
If a long time customer with a high balance makes a deposit for $50,000, and our boss wants to place a hold on it, what would you recomend: case by case or exception hold, and for how many days?