Compliance Blog

Posted by Anthony Demangone

Now that non-local checks are going bye-bye, we've been getting a ton of questions from people who are taking a close look at Regulation CC for the first time in a while.  Here's a fairly common question that we've been getting.  How long can we hold local checks for "new accounts?"

Well, here's the answer:

During the new account exception period, the schedules for local and nonlocal checks do not apply, and, unlike the other exceptions provided in this section, the regulation provides no maximum time frames within which the proceeds of these deposits must be made available for withdrawal. Maximum times within which funds must be available for withdrawal during the new account period are provided, however, for certain other deposits. Deposits received by cash and electronic payments must be made available for withdrawal in accordance with §229.10. Emphasis added.

Where did I find this?  Appendix E to Regulation CC - its Commentary section.  There's a TON of useful information there about how Regulation CC works.  The Fed did a good job of writing the requirements in narrative form, so the requirements are a bit easier to digest. 

We'll tackle more Reg CC issues in the weeks to come.  But for now...have a great weekend, everyone!