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Our Funds Availability disclosure states that we will make cash deposits available on the same day. However, we provide same-day availability only for cash deposits made with tellers; for cash deposits made at an ATM, we make $200 available immediately, with the remainder available the next day. Do we need to revise our disclosure? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Our Funds Availability disclosure states that we will make cash deposits available on the same day. However, we provide same-day availability only for cash deposits made with tellers; for cash deposits made at an ATM, we make $200 available immediately, with the remainder available the next day. Do we need to revise our disclosure?

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Yes, we recommend revising your disclosure. The disclosure should accurately reflect your institution’s practices, and it would not be accurate to state that all cash deposits will be available on the day of deposit. 

For resources related to our guidance, please see:

  • Regulation CC, 12 CFR 229.16(a) (“. . . a bank shall provide a disclosure describing the bank's policy as to when funds deposited in an account are available for withdrawal.”)