Answer:
The requirement is that funds have to be available by the later of 9 a.m. or the time at which your facilities (including ATMs) are open for business. For most banks, that means that 9 a.m. is the magic hour for availability.
If your system is flexible enough to allow you to release funds just prior to 9 a.m. (rather than at the end of the previous day's processing cycle or at midnight when the date changes), you can delay access until that hour. I hasten to point out, though, that "five-day" holds are unusual now that all checks are considered local. You could have a five-day exception hold if your bank wanted to limit the hold to that duration, but at least under the current Regulation CC rules, such a hold could be imposed to release funds on the seventh business day.
First published on BankersOnline.com 3/21/11
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