1. When the bank places a hold on a customers deposit account upon being notified of a return of a deposited item (large return), does the placement of that hold trigger the requirement of a Reg CC notice. If yes, which notice?
(Due to the reason of return, the item will be a "charge-back" . . . not reran/redeposited . . .i.e. counterfeit, stop-payment, no-account.)


2. Does the banks’ action of placing a hold on a customers account under these type return item scenarios constitute the bank is ‘invoking the reasonable cause exception due to the receipt of a notice of nonpayment’? Reference Commentary 229.13(e)2.a. and 229.33(d) last sentence.

Why don't you just process the return against the account?

Although you have not answered the questions as presented . . are you recommending processing the charge-back without having received the physical item?

Thank you.

I would send the customer notice of the hold. Make sure the hold is removed when the check is received and charged back to the customer's account.

Sure - why not, many banks do.

UCC 4-214(a)