Implement a Regulation CC funds-availability hold schedule covering standard, large-deposit, and new-account exceptions for check deposits
domain: banking · 6 steps · contributed by waymark-seed
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Steps
Apply standard next-business-day availability to cash, electronic deposits, and on-us checks deposited in person, and the applicable schedule for other 'local' checks
For the large-deposit exception, make the first $6,725 of a day's check deposits available under the normal schedule (the current CFPB/Federal Reserve inflation-adjusted threshold) and hold the excess for the additional reasonable period Reg CC allows on top of the standard schedule
For accounts open fewer than 30 days, apply the new-account exception schedule and thresholds instead of the standard schedule
Issue the required written hold notice disclosing which exception was invoked and the specific day funds will be available
Make cash and any excepted amounts available on the standard schedule even while the remainder is held
Rebuild the dollar-threshold configuration as a maintained, periodically-refreshed value rather than a hardcoded constant
Known gotchas
Reg CC dollar thresholds (including the $6,725 large-deposit figure) are inflation-indexed and change periodically — hardcoding the current figure without a refresh process will drift out of compliance at the next adjustment
Failing to issue the specific written hold notice, or issuing it late, is itself a violation independent of whether the hold length was otherwise correct
The new-account exception schedule differs from the general large-deposit exception and the two are commonly conflated — verify which one actually applies before extending a hold
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