Reg CC Availability & Non-Transactional Accounts

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Question:

I understand that Reg CC availability schedules do not govern checks deposited to nontransactional accounts. However, I have also read that if you give your Funds Availability policy to all account holders regardless of the type of account, as many banks do to avoid the possibility of failing to give it in required situations, that your actual availability policy for nontransaction accounts must match what your disclosure says. Should the bank add a clause to the disclosure or can we qualify the reference within the disclosure to read "funds deposit into your 'transactional' account may be delayed...."

Answer:

A good way to handle it if you have a booklet of disclosures you hand to all new customers is to prominently label the Funds Availability portion of your booklet "The following information on Funds Availability applies only to checking and NOW accounts."

Adapt the statement to reflect what you call your transaction accounts.

First published on BankersOnline.com 10/1/12