Hello.

Questions are:

1. If we take a check for deposit today and do not place a hold on the funds, can we place the hold tomorrow?
2. If we take a check for deposit today and place a hold on it, can we extend the hold tomorrow?
3. Scenario.
We successfully image a check and send it to our service provider.
Our service provider also images it successfully.
When the check gets to our correspondent bank, they reject the image.
The correspondent bank then returns the check back to us.

Can we then (if we want to re-deposit the check) place an extended hold on it for the reason of Reasonable Cause to Doubt Collectibility?

All the questions above assume we will give the customer a Notice of Hold form.

Thank you.

I'm not at all certain that your image quality problem should be your customer's problem, or that it is a valid reason to doubt collectibility of the check. For what reason was the image rejected by the correspondent?

I agree with John, your bank's branch capture system abilities and limitations are not valid reasons to invoke the "reasonable cause" clause of Reg. CC. You should only invoke this clause if you have reason to doubt the collectibility of the item presented by the customer because it is a fraudulent item, etc.

http://www.federalreserve.gov/pubs/regcc/regcc.htm

Reasonable cause to doubt the collectibility of a check — Doubtful collectibility may exist for postdated checks, checks dated more than six months earlier, and checks that the paying institution has said it will not honor. The general criterion for doubting collectibility is “the existence of facts that would cause a well-grounded belief in the mind of a reasonable person” that the check is uncollectible. The reason for your belief that the check is uncollectible must be included in your notice to the customer.