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#1356176 - 03/11/10 08:20 PM Reg CC Next-Day Availability & Armored Car Service
compliance kid Offline
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Joined: Jun 2007
Posts: 21
If an armored car acts as an agent for a deposit customer and delivers deposits, which include cash and checks, to an employee at the bank's money room for processing, is the deposit considered to be made "in person to an employee" for next-day availability purposes under Reg. CC?

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Deposits and Payments
#1356325 - 03/11/10 09:49 PM Re: Reg CC Next-Day Availability & Armored Car Service compliance kid
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
If the armored car service is the agent of the customer, the agent appears in person and the answer is yes.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1356384 - 03/11/10 11:03 PM Re: Reg CC Next-Day Availability & Armored Car Service John Burnett
compliance kid Offline
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Joined: Jun 2007
Posts: 21
Thanks John - one more question --- if the bank uses an external vault service, acting as the bank's agent, and the customer's armored car, acting as the customer's agent, delivers deposits to the bank's external vault service, is that deposit also considered to made "in person to an employee" for next-day availability?

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#1356572 - 03/12/10 02:49 PM Re: Reg CC Next-Day Availability & Armored Car Service compliance kid
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I knew the minute I clicked "Submit" on my earlier response that this question would arise. I don't have an answer. My logic tells me "No" because the vault service is not an "employee of the bank," but I put a confidence factor of 2 (out of 10) on that response.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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