Our front line staff creates the hold notice and then sends to the Fraud Dept to review and put on the system.
Often times the front line does the Hold Notice Wrong. If we change the Hold Notice we send the customer a new one. If we decide the hold is not necessary are we required to send notification to the customer informing them their funds are available sooner then we originally informed them?
What is your view on retention of the physical deposit hold notices to meet Reg CC retention requirements? We recently converted our core system and have the opportunity to electronically record data used to populate deposit hold notices rather than retaining the physical forms.The data will be in the form of a report rather than a customer view of the notice. Parameters are set in the system for hold types, hold days, and makes consideration for multiple hold scenarios such as large deposit hold for amount over $5,000, two day availability for $4,800, and next day for $200.There is also a required field for facts to support reasonable cause holds when confidential information is selected.
Could you give me your thoughts? Most believe Remote Deposit of check images are subject to Reg CC mandates. I have observed on BOL that this is not the rule, but is a best practice?
Does Regulation CC apply to savings accounts?
Has there been any update to the status of Regulation CC? We are getting ready to reprint disclosures, and wonder whether we should place our usual order or cut back to anticipate change.
Reg CC is for transaction accounts - both consumer and business. If a business has a large deposit exception hold placed for the wrong amount (held 7 days for full amount when it should have held the excess over $5,000 until the 7th business day) Is this error a Reg CC violation? Some say it is a business account so it doesn't count as a violation for Reg CC.
Can you tell me the required signage for an ATM?
Does the Dodd Frank Act or compliance require banks to process loan payments that are dropped off in the night drop after the night drop has been closed for the day but the branch drive through is still open?
The bank that I am currently working for states in their policy that if a customer wants to deposits an official check with a special deposit ticket the bank must verify the check with the issuing bank before they can use the special deposit ticket. Is this allowed as part of a policy? I have never heard of anyone doing this. There is nothing in Rec CC about verifying the check.
How can I simply define case by case holds and Reg CC holds?