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#2305573 - 01/31/25 05:51 PM REG CC Hold
banker-12 Offline
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Joined: May 2007
Posts: 1,247
If we have 3 checks being deposited totaling $1,000, $800 was cash out to the customer and the amount of the deposit is $200. The cash out was given because funds were in the account.
A hold was placed on one check for $500 because it was redeposited and returned unpaid. The hold notice states amount of deposit $500 and amount held $500. Should the amount of deposit on the hold notice be $200 since that was the amount deposited even if it's less than amount held?

Thank You

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Deposits and Payments
#2305577 - 01/31/25 06:05 PM Re: REG CC Hold banker-12
HappyGilmore Offline
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Joined: Jun 2004
Posts: 20,032
Pulling people out of the ditc...
how can you place a $500 hold on 3 checks totaling $1,000 if you disbursed $800 of the deposit? you don't have $500 to hold...
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#2305583 - 01/31/25 06:32 PM Re: REG CC Hold banker-12
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,936
Illinois
It's possible to place a hold that is larger than a deposit when cashing a check if you have the following clause in your funds availability disclosure.

C-6--Holds on Other Funds (Check Cashing)

If we cash a check for you that is drawn on another bank, we may withhold the availability of a corresponding amount of funds that are already in your account. Those funds will be available at the time funds from the check we cashed would have been available if you had deposited it.

The "amount of deposit" is not a required disclosure in 229.13(f) for an exception hold. The requirement is the "amount of deposit being delayed" which is the $500 being held. What is important from a regulatory perspective is that you communicate the amount of the hold being placed on the account, and if you have the correct disclosure language so you can hold funds in the account when cashing instead of depositing a check.
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#2305594 - 01/31/25 08:11 PM Re: REG CC Hold banker-12
banker-12 Offline
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Joined: May 2007
Posts: 1,247
Our disclosure does have that clause.

Thank you

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