10/01/2012
I understand that Reg CC availability schedules do not govern checks deposited to nontransactional accounts. However, I have also read that if you give your Funds Availability policy to all account holders regardless of the type of account, as many banks do to avoid the possibility of failing to give it in required situations, that your actual availability policy for nontransaction accounts must match what your disclosure says. Should the bank add a clause to the disclosure or can we qualify the reference within the disclosure to read "funds deposit into your 'transactional' account may be delayed...."
09/24/2012
If a customer deposits a cashier's check for $50,000 and the branch wanted to place a case by case hold, should the first $5000 still be made available and the remaining $45,000 held for two business days?
09/17/2012
According to Reg CC, does the bank have the right to delay availability for withdrawal of cash or similar means by one business day, and only provided $400 deposited fund available for cash withdrawal?
08/13/2012
I am an Internal Auditor and would like to know if the Notice of Availability is disclosed on a deposit envelope at the ATM, does that satisfy the sign display requirements?
06/25/2012
We have proprietary ATMs that accept deposits and process withdrawals. We are clear regarding both Reg E notices (on or at machine and screen/paper with specific fee). We are not clear on Reg CC. We know we need to include at each ATM the notice "funds deposited in the ATM may not be available for immediate withdrawal" as required by Reg CC 229.18(c). Do we ALSO need to post our Funds Availability Policy at each ATM location in addition to the notice (229.18c)?
06/04/2012
There seems to be some confusion with regard to the first $200 rule under Reg CC among some people who I've spoken with. Does it apply to exception holds placed for "doubtful collectability" or "redeposited checks"? What exception holds must use the $200 rule?
05/14/2012
My question pertains to the FDPA (Flood Disaster Protection Act) regarding the notification requirements to the borrower when a loan is modified. Is the bank required to provide the Notice of Special Flood Hazard and Availability of Federal Disaster Relief Assistance to the borrower when the loan is being modified? The modification was to lower the current rate on the existing loan. I have read the FDIC section 339.9 requirements, the 2009 Interagency Q and A's, and the Mandatory Purchase of Flood Insurance Guidelines (2007) and all are mute to the notice requirements pertaining to loan modifications.
04/30/2012
Title 12, Part 18 (Disclosure of Financial and Other Information by National Banks) requires national banks to display signage about the availability of the annual financial disclosure statement. I work for a formerly OTS-regulated federal thrift now regulated by the OCC. Isn't my bank now subject to this requirement?
03/19/2012
Are we required to give 2nd day availability on a Cashier's Check that is deposited into a New Account? Is the Exception Reason for New Account a valid reason on a bank's Cashier Check?
03/12/2012
On our Funds Availability sign, we have our main branch city and state. Should each sign have its location on it or do we even have to have a city and state on the signs?