Regulation CC Delays and Overdraft Fees

When you delay the funds from a customer’s deposit beyond your normal availability schedule, Regulation CC states you must provide the customer with notification. So, for example, you likely provide them with a case-by-case hold notice or an exception hold notice, depending on the type of hold/delay. If that notice is not provided to the customer at the time of the deposit, you are prohibited from charging the customer any type of overdraft or return fee if:

1. The overdraft/return would not have occurred if the deposit was not delayed; and,
2. The check was ultimately paid.

Kevin explains more in the video.

Published
2024/02/15