Reg CC and Debit Card Deposits

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Question:

Under Reg CC, how are deposits made by debit card treated? (These might be a deposit at an ATM or a merchant refund on a debit card burchase, as examples.) Can we hold these for three days even for existing customers?

Answer:

Deposits at proprietary ATMs must be provided the same availability schedule as deposits made at a teller window with the exception of next-day items that aren't US Treasury or on-us checks which can be treated as local checks if not deposited in person.

Deposits at non-proprietary ATMs can be held up to the 5th business day provided that your Funds Availability Disclosure states this along with how customers can distinguish between proprietary and non-proprietary ATMs.

Debit card refunds are electronic funds transfers and must be credited the day you receive them to comply with Regulation E and Visa/Mastercard Operating Rules.