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#966794 - 05/30/08 03:12 PM Reg CC/no notice for repeated hold - lockbox
TXBanker17 Offline
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Joined: May 2008
Posts: 10
I'm hoping I will get some answers to this....we offer lockbox services and use a correspondent bank. Well this bank does not give us immediate credit, but we have to post the deposit to the customer's account that day. The problem is they have a reserve sweep, that takes the funds at night and sweeps over to earn interest. We do not want them to earn interest on the lockbox deposit until next day but we do need to credit so that it affects their ledger balance but we don't want it affecting the available or collected.

We have tried everything, as far as assigning float with our system but we are unable to. One solution is to place a 1 day hold each day, but we do not want to give the customer notice. I told the person in charge of all this that we are required to give notice under reg cc and I don't think this is possible to do without the customer knowing.

Does anyone know of exceptions to reg cc where we can do this each day, or another suggestion?

Your help is appreciated...thanks!

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#968592 - 06/03/08 08:20 PM Re: Reg CC/no notice for repeated hold - lockbox TXBanker17
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,256
Galveston, TX
Holds do not impact the timing on which you have to pay interest on an account.

Sec. 229.14 Payment of interest.

(a) In general. A depositary bank shall begin to accrue interest or dividends on funds deposited in an interest-bearing account not later than the business day on which the depositary bank receives credit for the funds.
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#969600 - 06/04/08 10:35 PM Re: Reg CC/no notice for repeated hold - lockbox rlcarey
DebL Offline
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Joined: Jan 2007
Posts: 314
CA
rlcarey - If by sweep account murray means the funds go out to a repurchase agreement as opposed to sitting in an IBA at the bank, does the same rule apply?
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#969612 - 06/04/08 11:06 PM Re: Reg CC/no notice for repeated hold - lockbox DebL
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,256
Galveston, TX
If that is the case, it should be addressed in the sweep contract.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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