Disclosing Same Day Availability

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Question:

We disclose that we give same-day availability for cash and wire transfers because the funds are available to the customer if they come into the bank, but they are not available through the debit/ATM card network because we only send a positive balance file after we do our nightly update. Are we out of compliance by disclosing same day availability for these deposits?

Answer:

You are not required to make cash and wire transfer deposits available on a same-day basis by Reg CC. However, your current disclosure is inaccurate because it doesn't accurately reflect your practice. I suggest that you add a disclaimer indicating "next business day availability for ATM and Debit card access".

First published on BankersOnline.com 7/23/07