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Reg CC Hold NOT Given at Time of Deposit

Answered by: 
John Burnett

Question: 
Relative to Reg CC: the bank is using the case by case hold option. A customer comes into the bank and makes a deposit face to face with the teller. The teller determines that a hold needs to be placed. Is it acceptable to not give the written notice of hold at time of deposit and prepare it later in the day and mail it to the customer?
Answer: 

If the teller has determined at the time of the deposit that a hold will be placed, the notice must be given then. Only when the decision to place the hold is made after the deposit is taken, may the bank provide the notice later. From a very practical perspective, if the hold will be a local check (available on the second business day following the banking day of deposit), the notice is useless to the customer unless given at the time of deposit (unless you want to have your bank making phone calls).

First published on BankersOnline.com 3/22/10

First published on 03/22/2010

Filed under: 
Compliance
Filed under compliance as: 
IT
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