This is no longer a Reg CC issue, because you are not delaying availability of a deposited item. You are charging back a previously deposited item. Whether you should place a hold until the item arrives or charge the account immediately will most likely depend on your overall relationship with this depositor and the reason for return. One other thing to keep in mind is your midnight deadline. Once you have notice of the return, you're on the clock for informing your depositor, even before the item gets back to you.