While Regulation CC requires a written notice whenever you place a hold on funds deposited into a checking account, we are not aware of any similar regulatory requirements that would apply to placing a hold on funds deposited into a savings account.

Regulation DD, which covers savings accounts, does not include any funds availability requirements. Meanwhile, Regulation CC does not apply to savings accounts. See 12 CFR 229.2(a) (Reg. CC’s definition of “account”). Consequently, whether you hold the portion of the check deposited into the savings account depends on your institution’s policies and your account agreement with the customer.

Needless to say, the Reg. CC notice requirement will apply to any hold placed on the amounts deposited into the checking account. If you place a large item hold on amounts in excess of $5,000 that are deposited into the checking account, the hold notice should reflect the amount of the deposit into the checking account that is being held. But that notice does not need to include any held amounts attributable to the deposit into the savings account. 12 CFR 229.13(g)(1).

Notwithstanding the above, note that your institution may have voluntarily agreed to comply with the Reg. CC funds availability requirements for all accounts, including savings accounts (for example, in the savings account agreement or signature card). If that is the case, you will need to honor those provisions by issuing a written hold notice on any funds deposited into the savings account, as well. In such case, we do not see any problem with either providing separate hold notices for each account or combining the hold notices for both accounts.