Reg CC & redeposits

Question: Do we have to make the first $100 available on a check that is re-deposited after it was returned for NSF?

Answer: A check that is re-deposited after bouncing once is not protected by Regulation CC. The regulation protects consumers who deposit checks, not rubber. This check is already suspect because it has been returned. You have reason to believe it may not be paid. On top of that, you probably have already made the first $100 available when it was deposited the first time. Once is enough. Consumers can't get extra money by re-depositing bad checks.

Another way to explain this is that checks are only protected by Regulation CC the first time around. When checks reappear, they do so without the status they had the first time. When learning the rules about hold limitations on checks, tellers should also understand that not all checks are subject to the hold limits. Every now and then, there is such a thing as a bad check.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 4, 5/02