Sure.

Did anyone come up with a statement message yet? If so, can you share?

Effective xx/xx/xx: Depending on the type of check that you deposit, funds may not be available until the fifth business day after the day of your deposit. The first $200 of your deposits, however, may be available on the first business day.

Very nice. Thanks.

I thought so too.

Actually, this was addressed in the March 25th proposal and it was indicated that the transfer date was the effective date for the change from $100 to $200 whether or not the new regulations were issued or not. The proposal includes the updated regulatory language and model forms to support the change:

http://edocket.access.gpo.gov/2011/pdf/2011-5449.pdf

I realize we must inform our customers within 30 days of changing our policy. We have pre-printed account disclosures for new accounts. Is it ok to do an insert for this change (so we can use the supply we have already)?

Yes. It would also be acceptable, if not aesthetically pleasing, to do pen-and-ink changes to your current supply.

Has anyone come up with a condensed message that can go on the statements that they are willing to share? Our bank is very limited on space.

Please disregard the last post. I see where rlcarey replied earlier in the post. Thanks.

I can't remember why, but we choose the second day instead of the fifth day,
so for us - we would change Rick's language to:
.....depending on the type of check that you deposit, funds may not be available until the SECOND day after...."

"second" substituted for "fifth", right?

Our lobby disclosures also say 2. I think this is in line with using a case-by-case hold. We also use exception holds.

I believe a statement message would do. Has anyone come up with a statement message yet that they would be willing to share? We are limited to very few characters with our statement messages, so I just wanted to get some ideas of how to make the message short and sweet, but give them what they need.

See RLCarey's post in this same thread...short, sweet and to the point.

Wow. Thanks Doug! It's been a long Monday. I looked through teh thread before I posted, but totally missed that. Thanks!

If we do not do case by case holds, do we need to disclose the change of $100 to $200 available for withdrawal on the business day after deposit?

Generally, the $100/$200 disclosure only applies to banks that (1) don't generally provide next-day availability, (2) do provide next-day availability but may impose case-by-case holds, or (3) generally provide next-day availability, but may impose both case-by-case holds and exception holds.

Banks that have general next-day access and don't impose case-by-case holds don't have a $100 disclosure requirement.

Randy, shouldn’t your suggested language state "funds may not be available until the second business day after the day of your deposit." to reflect that the five day case-by-case hold is now gone since there are no longer any nonlocal checks?

Probably - But that is still the language that they use in the new proposed Model C-3 - although they also seem to still reference the $100 in the proposed model. You can tell they rushed the proposal to the presses.

John, am I understanding it correctly that if we're a bank using model form C-2 with next day availability and no use of case-by-case holds, then the entire $100/$200 transition should be a non-event for us?

Since there is no mention of the $100 availability in Model C-2, I would say non-event.

Thanks!

RE: rlcarey's sample language ... "Effective xx/xx/xx: Depending on the type of check that you deposit, funds may not be available until the [second] business day after the day of your deposit. The first $200 of your deposits, however, may be available on the first business day." ...

The model notice in the regulation says the $200 "will" be available on the first business day vs. "may" be available. Is there a reason for using "will" vs. "may" in this sentence?

Thanks.

"May" reflects a case-by-case application while "will" indicates something that happens in most cases under discussion. We are generally a next-day availability bank; therefore, I would use "may" in the first sentence and "will" in the second.

Thanks Brenda. We are case-by-case also and used to say "may" in the first sentence and "will" in the second sentence. Somewhere along the line that was changed to using "may" in both sentences. I'm not sure why and was wondering when using "may" vs. "will" would be appropriate.