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Can we place a hold on a check that is deposited into a savings account, and how should we notify the customer of such a hold? – IBA Compliance Connection

IBA Compliance Connection

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Can we place a hold on a check that is deposited into a savings account, and how should we notify the customer of such a hold?

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Yes, you may place a hold on a check deposited into a savings account. Regulation CC applies only to transaction accounts, and it does not impose any notice requirements on savings accounts.

Any notice requirements would depend on your account agreement with a customer. If you have voluntarily agreed to comply with the Regulation CC funds availability requirements in a savings account agreement or signature card, you will need to honor those provisions by issuing a written hold notice when holding deposits. It also is possible that your account agreement imposes other notice requirements for savings account holds. In the absence of any applicable language in your account agreement, it would be a best practice to provide some sort of notice to the customer in a reasonable period of time.

For resources related to our guidance, please see:

  • Regulation CC, 12 CFR 229.2(a) (“account means a deposit as defined in 12 CFR 204.2(a)(1)(i) that is a transaction account . . . .”)
  • Regulation CC, Official Interpretations, 12 CFR 229, Paragraph 2(a), Comment 1 (the definition of account “does not cover time deposits or savings deposits”)