Banker's Compliance Consulting Blog

Exceptions Holds for Being Repeatedly Overdrawn

Written by Kevin Edwards | Feb 17, 2025 4:06:43 PM

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:

  1. 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

  2. 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.


Published
2025/02/17