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Tuesday, June 23, 2009

How to Avoid a $500,000 Penalty.

OK, the headline is shamelessley sensational, but who would read about "Placing Holds on Checks"? Remember the cartoon strip "Calvin and Hobbs"? They would come up with games where they would make up the rules as they go; things would get pretty convoluted and quite hilarious! Regulation CC, or the Expedited Funds Availability Act kind of reads like that. Definitely a regulation that was written by committee.

Financial institutions are limited to the types and lengths of holds on checks and "must disclose their hold policies to all account holders, and make the policy available in written form upon request by any customer. It must also be provided at the time of opening of all new accounts. Additional disclosures are required on deposit slips, at ATMS, and when policy is changed in any way". Wikipedia.

Wikipedia has a pretty good chart that details the rules related to check holds. http://en.wikipedia.org/wiki/Expedited_Funds_Availability_Act

Make sure that your Reg CC policy is posted in your lobby, policies and disclosures are up to date, and be sure employees are TRAINED to understand the requirements. It IS true . . . penalties for non-compliance can run as high as a half a million dollars!

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