IBA Compliance Connection

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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?

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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.” )