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Reg CC Holds

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  • #32659
    Vicki Kramer
    Participant

    Good afternoon. Got something new this morning…

    A Personal Banker has requested to place a Large Deposit Exception Hold on a deposit. And, she wants to place a Case-by-Case Hold on the first $5,525 that is exempt from the Large Deposit Exception Hold. She provided a Reg CC Quick Reference Guide dated July 1, 2020 from some source that recommends this.

    I answered no because one hold will cancel out the other. Also, it appears to me that that practice would be circumventing the regulation and would be considered harmful to the consumer.

    Is this practice allowed?

    Thanks in advance for your help!

    #32662
    rcooper
    Keymaster

    As long as it isn’t a next day item you could place both a case by case and large deposit hold. The large deposit would apply to amounts over $5,525 and the case by case could apply to the first $5,525 if it is not a next day item. As with any other case by case hold you’d need to make $225 availabe the next day business day.

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