Ok so I am the old dog and for as long as Reg CC has been around and yes, I've around longer than it has, we have been making a copy of the check we placed a hold on and have attached it to our copy of the hold notice. Well the new dogs want to stop this. My question is this-when examiners come - do they ask you to prove the hold notice you have is correct by making produce a copy of the check?

How do you all handle this. Thanks-this is such a good brain pickin/opinion site. Heck-maybe there is actually some regulation that says to do this. I don't know. I'm depending on you to set me straight. Thanks again.

for my records, i keep a copy of the check...why not? it does make things a heck of a lot easier come exam time. it's just extra work when the examiners come and then you have to pull images of all the held checks they want to see.

ps-- when i worked for washington mutual, tellers had to make copies of all checks placed on an exception hold and file it in the branch file with the copy of the hold notice (receipt)--this was not required for case-by-case holds though

We have a case-by-case funds availability policy and we DON'T have tellers make copies of the items. The examiners request a small sampling and even if they want to see copies, it's still less costly to pull only the items under review (image)then have tellers make a photocopy at the time the hold is being placed.

You guys have got to quit giving the examiners the rope to hang you with. You are not required and should not keep copies of individual hold notices. The only exception to this is hold notices for one specific type of exception hold - "Reasonable Cause to Doubt Collectibility". Those you need to keep for two years. Everything else should be destroyed after you complete your back room quality control check on your holds. You do have a back room QC process, right? If not, put one in place. It will help you eliminate errors to begin with and that's what you are going to point your examiners to when they ask for copies of your hold notices.

In spite of the fact that you're not required to keep most of the hold notices you generate the examiners continue to ask for them when they come in. But I've never had one challenge me when I've told them that I don't keep any except the Reasonable Cause exception hold notices. I generally can provide them with some notices that are currently in our QC process and then also provide them with the documentation of our procedures, training, QC process, and management response to QC findings. This is all Reg CC requires that you have to document compliance.

Amen! We also do not keep copies of any hold notices except when we are required to. We have a QC function w/management response, quarterly training (with meticulous records), and thorough procedures. We also have never had an examiner challenge this process.

Thank you.
Wendolene-I have to comment on your quotation. How fitting-if we could only say that to a few people out loud!!!