No, we are not aware of any Illinois law or rule that would limit holds placed on items deposited into savings accounts. Additionally, because Regulation CC does not apply to savings accounts, we are not aware of any federal requirements for placing holds on items deposited into savings accounts.

Any notice obligations would depend on your savings account agreements. 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 creates other notice requirements for savings account holds.

In the absence of any applicable language in your account agreement, we believe it would be a best practice to provide some type of hold notice to the customer within a reasonable time, possibly by using the Regulation CC model notices as a guide.

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, Paragraph 2(a), Comment 1 (The definition of account “does not cover time deposits or savings deposits . . . .”)

• Regulation CC, Appendix C, Model Availability Policy Disclosures, Clauses, and Notices