Topic: Regulation CC
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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?
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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…
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We make all cash deposits at ATMs available immediately. Since we do not distinguish between deposits at proprietary and nonproprietary ATMs, do we need to disclose a list of locations for our proprietary ATMs in our Regulation CC disclosure?
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No. Regulation CC requires you to disclose a list of the locations for your proprietary ATMs only if you delay the availability of cash deposits made at nonproprietary ATMs. For resources related to our guidance, please see: Regulation CC, 12 CFR 229.16(b)(5) (“The specific availability policy disclosure shall contain the following, as applicable . .…
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Regulation CC requires us to include “a notice that deposits may not be available for immediate withdrawal” on our preprinted deposit slips. Do we need to include this language on our counter deposit slips?
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No, you are not required to include the Regulation CC notice on your counter deposit slips. The Official Interpretations for Regulation CC clarify that “a bank need not include the notice on deposit slips that are not preprinted and supplied to the customer — such as counter deposit slips . . . .” For resources…
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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…
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Is there any law or regulation that requires cash deposits to be made immediately available?
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No, we are not aware of any law or regulation that requires immediate availability for cash deposits. Regulation CC does not require immediate or even same day availability for cash deposits. At most, it requires next-day availability for cash deposits, electronic payments, and certain check deposits. For resources related to our guidance, please see:…
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Can we place a hold on a check that is deposited into a savings account, and how should we notify the customer of such a hold?
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Yes, you may place a hold on a check deposited into a savings account. Regulation CC applies only to transaction accounts, and it does not impose any notice requirements on savings accounts. Any notice requirements would depend on your account agreement with a customer. If you have voluntarily agreed to comply with the Regulation CC…
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Currently, we provide next day availability for deposits, but our cash letters are processed on a same day basis. Since we receive same day availability for deposited funds, are we required to provide customers with same day funds availability?
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No, we are not aware of any requirement to provide your customers with same day availability for deposited funds, even if your financial institution receives same day availability for deposited funds. Regulation CC does not require same day availability for any type of deposits; the fastest funds availability schedule is next day availability for cash…