Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
Currently our deposit cut-off time is 3:00 p.m. for in office deposits and 9:00 p.m. for internet and mobile banking deposits, which is disclosed in our Regulation CC disclosures. Soon, we will be installing a teller capture system, and we are considering using each bank’s individual closing time as the cut-off time for that particular bank. Can we disclose our in office cut-off time as 5:30 p.m., which is the latest that any of our offices close? Or do we have to disclose each office’s individual cut-off time? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Currently our deposit cut-off time is 3:00 p.m. for in office deposits and 9:00 p.m. for internet and mobile banking deposits, which is disclosed in our Regulation CC disclosures. Soon, we will be installing a teller capture system, and we are considering using each bank’s individual closing time as the cut-off time for that particular bank. Can we disclose our in office cut-off time as 5:30 p.m., which is the latest that any of our offices close? Or do we have to disclose each office’s individual cut-off time?

—

by

We recommend disclosing the actual cut-off time for each location.

Regulation CC permits your bank to set different deposit cut-off times for different locations and for different types of deposits. However, your disclosures should accurately reflect your institution’s practices, and it would not be accurate to state that 5:30 p.m. is the cut-off time for all in-office deposits if some of your branches close earlier than that. 

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.”)
  • Regulation CC, 12 CFR 229.19(a)(5)(ii) (“Funds may be considered deposited on the next banking day, in the case of funds that are deposited — After a cut-off hour set by the depositary bank for the receipt of deposits of 2:00 p.m. or later, or, for the receipt of deposits at ATMs, contractual branches, or off-premise facilities, of 12:00 noon or later. The banks may set different cut-off hours for the receipt of different types of deposits, or receipt of deposits at different locations.” )