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Does Regulation CC require us to provide advance notice before we extend our business day and our cut-off time for deposits from 4:00 to 5:00 p.m.? – IBA Compliance Connection

IBA Compliance Connection

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Does Regulation CC require us to provide advance notice before we extend our business day and our cut-off time for deposits from 4:00 to 5:00 p.m.?

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No, you do not need to send advance notice of the change. Because you are extending your business hours by one hour, which will have the effect of expediting the availability of funds, Regulation CC does not require advance notice of the change. It does require you to provide notice to your customers no later than thirty days after making the change.

For resources related to our guidance, please see:

  • Regulation CC, 12 CFR 229.18(e) (“A bank shall send a notice to holders of consumer accounts at least 30 days before implementing a change to the bank’s availability policy regarding such accounts, except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation.”)