Answer:
Answer by Jim Bedsole: Savings accounts are not considered transaction accounts under Reg CC, so they are not subject to Reg CC hold limitations. However, some institutions have chosen, by way of disclosure, to make them subject to the same hold policies as their transaction accounts. Also, some states have hold limitations as a matter of state law that may apply.
Answer:
Answer by Sonja Kriegsmann: Reg CC doesn't apply to savings account, so the limits in Reg CC would not apply to deposits into a savings account. The length of the hold you place may depend on a variety of things including state law, the wording of your funds availability policy and if this policy is provided to individuals that open savings accounts as well as checking accounts. You may also want to review your deposit contract in the event it covers this topic. Training and what your CSRs advise customers may also play a role here - if either of those result in your customers believing that your normal funds availability policy would apply to savings accounts, you should follow your normal policy. If none of these items address the length of holds on savings accounts, you would be free to place a hold of any time you choose without a violation of Reg CC.
First published on BankersOnline.com 4/15/13
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