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Reg CC Holds on Treasury Checks

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Question: 
Can a US Treasury check be placed on a funds availability hold and for how long?
Answer: 

If the check is deposited to a new account (the customer had not had a transaction account with your bank within 30 days of the first deposit to the account), you can hold the excess over $5,525 in next-day availability checks (including the US Treasury check) for up to 9 business days from the banking day of deposit. The first $5,525 of such checks deposited must be available by the first business day after the banking day of deposit.

If the account is not a new account, and the Treasury check is deposited in an account of a payee of the check, it is a next-day check. If it is deposited in an account of a person who is not a payee of the check, it has no special status. Unless there is an exception hold, the first $5,525 of next-day checks deposited on a banking day is to be available by the next business day after the banking day of deposit; the rest of the checks deposited must be available by the second day after the banking day of deposit unless the bank places an exception hold.

Exception holds that can affect a Treasury check include a large deposit hold (affects the excess over $5,525 in checks deposited), a chronic overdrafter hold (which affects the full amount of deposited checks) or a reasonable doubt hold, which would be rare with a Treasury check, but possible.

First published on 01/22/2023

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