Banker's Compliance Consulting Blog

Regulation CC: Case-by-Case Delays

Written by Kevin Edwards | Jan 31, 2023 5:25:54 PM

Regulation CC outlines when you are required to make funds from deposits available to your customers. That timeframe is generally dictated by your funds availability policy (same day, next day, etc.), but even then, there are some restrictions when it comes to certain types of deposits. The Regulation allows you to delay funds even longer by placing either a Case-by-Case or Exception hold.

Kevin explains Case-by-Case delays in the video.

 

Transcript:

I've mentioned case-by-case delays several times as we've been going through here. And just think this is another category of holds that you can put in place. And we're going to go through the rules here. And the rules tend to muck things up. So I know a lot of financial institutions don't even take advantage of this, but think of this as, so these are slightly different. So remember when I mentioned at the beginning of the program, those next-day items, well, those you cannot take a case-by-case delay. That's what we're getting at E1 at the top of the page; you cannot take a case-by-case delay on those next-day items. Now, for everything else that we're going to talk about here, if you're going to use this case-by-case delay, you have to give them $225 of that check amount. Okay?

So they get some walking around money while you hold their check for that amount of time. And it's not very long. It still has to be available on that second business day for personal checks and things along those lines. But the nice thing about case-by-case is that it's automatic. You don't have to give them a reason. So you can delay it until the second business day, and you don't have to give them a reason.

Now in the middle of your page, page seven, there's another table that lays out what we're talking about here. So those next-day items, electronic cash deposits on us. For those categories, you can't use a case-by-case delay. So they still have to be available the next business day. Now, personal checks. So that's what these case-by-case delays are talking about. You can delay those to the second business day. You don't have to give them any reason, but you cannot delay that $225. Okay? So that's case-by-case delays. They're different than those exception delays.

Published
2023/01/31