Question #1 - Are we able to place a Reg CC hold on a CD? With all the fraud going on I feel we should be able to place a hold to reduce the risk to the bank.

Question #2 - Can we put time limits on redemption of CDs? We understand that a customer will have to pay a penalty for taking money out of the CD or cashing it in, but can we make it a bank policy that a customer can not cash in a CD or have activity in the CD for say 15 business days?

Reg CC would apply to a time deposit, but not many banks open CDs with non-on-us checks. There is no requirement to allow a CD to be withdrawn early.

Why would a CD apply to Reg CC as it's not a transaction account?

And if there is no requirement to all a CD to withdrawn early, I guess that will be management's decision to implement a time frame on this.

SMH - you are correct. I was thinking Reg DD.

No worries...

Putting a hold on a CD would be a managments decision then since it's not regulated by Reg CC? We won't get cited by an examiner for doing so?

Reg D has specific requirements for withdrawals from a CD and requires penalties to be assessed if the withdrawals are within the first six days, etc. But nothing in Reg D says that you must allow withdrawals, that you cannot set a specific time limit on any allowed withdrawals, or the amount of any other early withdrawal penalty that you may assess in addition to the prescribed minimum interest penalties.

rclarey, gotcha. Thanks

Some banks have issued "no early withdrawal" time deposits for years. You could borrow against the CD if you needed to, but could not withdraw early.