Regulation CC: Large Deposit Exception Holds
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Regulation CC addresses when you must make deposited funds available. It also outlines when you can delay availability even further and how long you can delay the availability of certain deposited items. There are case-by-case holds, exception holds, etc. One common area of confusion is when you have large deposit, which is defined as anything above $5,525.
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Wouldn’t it be nice to not have to fill out a deposit hold notice every time you want to do a deposit delay?
Many of you may not know this, but in parts of Reg CC there is just that gift for you. Let me draw your attention to something we don’t do very often and I’ll give you the Roman net here. It’s 229.13G3, G3 of 13 says that whether consumer or business, doesn’t matter, if you have a customer that has repeatedly overdrawn their accounts. And how do we measure that? We look backwards six months and say they were overdrawn or would have been overdrawn had we not rejected checks. Then we can consider them to be a repeated over drafter. And so for the next six months, we’re going to give you one notice that says every time you bring in a deposit, we’re delaying it for an exception hold reason, which is seven business days.
For the next six months, we can give one notice now that covers that we don’t have to fill out a deposit delay notice every single time. Now in addition to that, that’s consumers and businesses you can do that for. For businesses, not consumers, you might have a business that regularly brings in large deposits and maybe there’s some more risks there than you’re willing to accept. You can say every time you bring in a large deposit, we’re going to delay it. It’s not just for six months, it’s forever. Now one notice forevermore every time you bring it in a large deposit, meaning more than $5,525, we’re going to delay it for seven business days.
Now, again, whether this is great customer service or not, but if you find that you’re regularly filling these out and you’re maybe having errors and things like that give them a on-hold one time standing order, if you will, here we go. We’re always going to relay it. I hope that that’s of help to you. If you have questions about this or other parts of Reg CC or any other compliance regulations, we’d love to help you out. Don’t hesitate to give us a call. Thanks for watching.
Published
2021/02/08
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.