Exceptions Holds for Being Repeatedly Overdrawn
Regulation CC outlines when institutions can delay deposited funds using an exception hold. These include instances of large deposits, redeposited checks, repeated overdrafts, reasonable cause to doubt collectability, and emergency conditions. Each of these categories; however, have specific rules you need to follow not only to maintain consistency but ultimately compliance. For example, what exactly does it mean to be repeatedly overdrawn? First, this reason, unlike some of the other exception hold reasons, has nothing to do with a specific check. Rather it has to do with your customer and how they handle their account. You can use the repeatedly overdrawn reason when:
- On six or more banking days in the previous six months, the account had a negative balance, or would have had a negative balance if checks and charges had been paid; or
- On two or more banking days in the previous six months the account balance was negative in the amount of $5,525* or more or would have been had all checks and charges been paid.
*Will increase to $6,725 on July 1, 2025.
Kevin explains more in the video.
2025/02/17
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).