Will you please help me on handling the $450 availability after 5 pm on the second business day of a case-by-case hold if we choose to hold the funds an extra day? If we close at 4 pm or 5 pm, does this mean effectively those $450 funds would have to be available at our ATMs after 5 pm on that second business day?

Yes, unless your ATM limit is less.

2. The EFA Act recognizes that the $450 that must be provided on the day specified in the schedule may exceed a bank's daily ATM cash withdrawal limit, and explicitly provides that the EFA Act does not supersede the bank's policy in this regard. The Board believes that the rationale for accommodating a bank's ATM withdrawal limit also applies to other cash withdrawal limits established by that bank. Section 229.19(c)(4) of the regulation addresses the relation between a bank's cash withdrawal limit (for over-the-counter cash withdrawals as well as ATM cash withdrawals) and the requirements of this subpart.