Question & Answer

Question: Our Direct Deposits are posted to be available on the day instructed, and are available in our bookkeeping area and over the window in the branch. But our ATM processing is done by our vendor, and there is a one day delay on those deposits. A customer has complained because she can't get her pay from the ATM on the morning it is supposed to be available-even though she could come into the branch and cash a check against her account. Is there anything in the regulations that covers this?

Answer: This was a tough one! Our contacts at the Federal Reserve answered this way: Regulation CC says that you are permitted to make electronic funds available the day following receipt. But, of course, you MAY make them available immediately. If your Reg CC disclosure says that electronic funds transfers will be available "no later than the day following receipt" then you are covered in both over the window and through the ATM availability. If, however, your disclosure says they are available "immediately", it was their opinion that they should be available at your ATM as well as at the teller's window and in bookkeeping on the day required.

Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 2, 3/91