Deposits On Mobile Device Covered Under Reg CC?

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Question:

Are deposits made on a mobile device covered under Regulation CC? If not, is it safe to say we can hold as long as we like?

Answer:

Current interpretations of Regulation CC will lead to a conclusion that they are not covered. As far as holding them for "as long as we like", I think you need to consider any excessive holds times weighed against a possible UDAAP citation. Whatever you decide, it should be clearly communicated in your mobile banking agreement.