Regulation CC (Exception Holds-Reasonable Cause to Doubt Collectability )

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    Our current process for placing an exception hold for “reasonable cause to doubt collectability” is that it must fall into one of these categories: bank received notice that the check is being returned unpaid, bank has confidential information that indicates the check may not be paid, check is drawn on an account with repeated overdrafts, bank is unable to verify the endorsement off a joint payee, some information on the check is not consistent with other information on the check, there are erasures or other apparent alterations to the check, the routing number of the paying bank is not a current routing number, or the check is postdated or has a stale date. The information must be factually based and if it does not fit one of the categories we would not place the hold. We are wanting to verify that these are valid reasons for placing an “exception” hold specifically on US Treasury Checks. We have had some issues with holds being placed on US Treasury Checks and want to make sure we are providing the correct guidance to retail.


    If certain conditions are met, U.S. Treasury Checks must receive next day availability. I have found that the tool provided by the FDIC (link below) can be very helpful in determining the timeline for the different types of checks. The entire document is helpful, but the charts start 25 pages in…

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