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Currently, we provide next day availability for deposits, but our cash letters are processed on a same day basis. Since we receive same day availability for deposited funds, are we required to provide customers with same day funds availability? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Currently, we provide next day availability for deposits, but our cash letters are processed on a same day basis. Since we receive same day availability for deposited funds, are we required to provide customers with same day funds availability?

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No, we are not aware of any requirement to provide your customers with same day availability for deposited funds, even if your financial institution receives same day availability for deposited funds. Regulation CC does not require same day availability for any type of deposits; the fastest funds availability schedule is next day availability for cash deposits, electronic payments, and certain check deposits. Provided that you follow the funds availability rules for deposits, we do not believe that your institution is required to make any funds available on a same day basis.

We note that there are some nascent efforts to speed up payment systems generally, including a NACHA plan to provide same day processing for ACH transactions. However, none of those efforts have been finalized or implemented.

For citations related to our guidance, please see below: