Reg CC - Counting the Days.....

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Question:

We are in disagreement on Reg CC. One person reads Reg CC to state that all new account holds should fall off the ninth business day. Someone else reads that as only stating next day items as falling off on the ninth business day and local or nonlocal can be held till the eleventh business day. Which one is correct? Also, is there an exact way to train Reg CC? One trainer trains on a two day hold, counting the day after the deposit is made and then backing up a day for availability. (Deposit made on Monday, count Tuesday, Wednesday the backing up and funds fall off on Tuesday available Wednesday.) Another trainer trains counting the day of the deposit then funds fall off the night of that second day. (Deposit on Monday: count Monday, Tuesday and funds available on Wednesday.) Both outcomes come out the same, but we are wondering if the Reg would lean one way or another.

Answer:

Answer by David Dickinson: Here's how we address this issue in our Advanced Deposit Operations Manual: Reg CC requires funds to be available on the _____ (2/5/7/11) business day following the day on which the deposit is made. For example, a local check deposited on Monday the 1st and delayed for an "exception hold" reason must be available on Wednesday the 10th (7 business days later).

Answer:

Answer by John Burnett: Unless you disclose to new customers how long holds will be, the only limits under the new account exception apply to cash and electronic credits (no holds permitted) and next day items including traveler's checks (the first $5,000 on a next-day basis and the rest within nine business days). You are not restricted at all (other than by your own disclosures) on how long you can hold local, non-local and even on-us checks, provided you use the new account hold exception.

First published on BankersOnline.com 11/26/07