This topic has us spinning around in circles as well. So, the general consensus here is that the Reg CC lobby notice would NOT reflect the possibility of a 7-day exception hold?

Some members of our team are making the point that a customer could come back when they do not not have access to their funds on day four (because of an exception hold we placed) and point to the sign and say, "But your notice says you can only delay the availability up to the 2nd day. What gives?"

Or is that why it is called an "exception" hold in the first place? As long as the initial funds availability disclosure indicated that you reserved the right to place such an exception hold, the sign in the lobby only needs to reflect the "general" policy.

At the end of the day, we'd like to have the lobby notice reflect the 7-day maximum for an exception hold.

A review of the notice revealed that the phrase is not in the notice. It will cost quite a bit to have it added to signs in all branches and if it is not absolutely required I don't want to go to the added expense. Of course if it is required we will make the change. I did not mean to infer that we didn't give same day credit, just whether we need to say so on the notice.

(b) Locations where employees accept consumer deposits. A bank shall post in a conspicuous place in each location where its employees receive deposits to consumer accounts a notice that sets forth the time periods applicable to the availability of funds deposited in a consumer account.

1. This paragraph describes the statutory requirement that a bank post in each location where its employees accept consumer deposits a notice of its availability policy pertaining to consumer accounts. The notice that is required must specifically state the availability periods for the various deposits that may be made to consumer accounts. The notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits. For example, the notice might be posted at the point where the line forms for teller service in the lobby. The notice is not required at any drive-through teller windows nor is it required at night depository locations, or at locations where consumer deposits are not accepted. A bank that acts as a contractual branch at a particular location must include the availability policy that applies to its own customers but need not include the policy that applies to the customers of the bank for which it is acting as a contractual branch.