Exception Tracking Spreadsheet (TicklerTrax™)
Downloaded by more than 1,000 bankers. Free Excel spreadsheet to help you track missing and expiring documents for credit and loans, deposits, trusts, and more. Visualize your exception data in interactive charts and graphs. Provided by bank technology vendor, AccuSystems. Download TicklerTrax for free.
Reg CC quinquennial inflation adjustments for funds availability
Has it really been five years since the first set of inflation adjusted thresholds for Regulation CC funds availability? It must be true, because the Federal Reserve Board and the Consumer Financial Protection Bureau yesterday issued the second quinquennial set of adjustments, with a compliance date of July 1, 2025, a little over 14.5 months from now. Here are the new amounts, based on the regulatory formula for adjustments and a 21.8 percent increase in the CPI-W between July 2018 and July 2023:
- The "next day" minimum availability amount will increase from $225 to $275
- The cash withdrawal amount in § 229.12(d) will increase from $450 to $550
- The new account, large deposit threshold, and repeatedly overdrawn thresholds in § 229.13 will increase from $5,525 to $6,725
- The civil liability minimum and maximum for individuals actions in § 229.21(a)(2)(i) will increase from $100 and $1,100 to $125 and $1,350
- The civil liability maximum for class action in § 229.21(a)(2)(ii)(B) will increase from $552,500 to $672,950 or 1 percent of the bank's worth, whichever is less.
Will we still be using checks five years from now? The next 5-year adjustment announcement is scheduled for the spring of 2029, with a compliance date of July 1, 2030. Will the rest of Regulation CC be updated by then?
Compliance and operations officers who recall the first such announcement that increased the Regulation CC dollar amounts as of July 1, 2020, should also remember that § 229.18(e) requires that changes to funds availability policies that are favorable to consumers (all of these dollar amount changes are favorable) require a notice to affected consumer account holders no later than 30 days after the changes are effective, even if mandated by the regulation.