Can we notify existing customers of changes in availability by verbiage on their monthly statement and does anyone have a model of language that could be used?

Here is an example from another thread:

"Normally funds deposited by check are available the next business day after the day of deposit. After 2/27/10 funds may be delayed until the 2nd business day after deposit. In limited cases funds may be delayed until the 7th business day."

As Reg CC applies to all transaction accounts including businesses, should this notice be sent to business customers too. I am getting some conflictinmg information that states the notice need only be sent to consumers.

Reg CC covers all transaction accounts (DDAs and NOWs), consumer and business. So yes, you would need to provide the notice to the business customers also.

John:

I have reviewed several of the questions and answers regarding Regulation CC for holding funds on a return hold and some are very dated.

My question is: If we receive notice today at 3:30 pm for a return item and we just memo post the customer's account until the item is received tomorrow morning. Does the memo post, which is only a temporary hold, constitute a hold under Reg CC and would a Delay Funds Availability notice be needed?

Thanks,
Kathy

I thought I remember discussion in a different post that business accounts are covered by Reg CC but you don't have to send notices on those accounts. Could anyone please advise on this.

(e) Changes in policy. A bank shall send a notice to holders of consumer accounts at least 30 days before implementing a change to the bank's availability policy regarding such accounts, except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation.

You're correct. The reg indicates notice must be sent on "consumer accounts". We are sending notice via statement message, and at present cannot differentiate between consumer and business when processing our statements, so we just sent it to everyone. Plus it is customer service, too!

Thanks!!!! I thought I understood no for business but as confused as I am, it wouldn't surprise me to read it incorrectly!!