Just a friendly reminder that on July 1, 2020, Regulation CC deposit delays will undergo some changes.
Specifically, the current $200 that must be made available when placing a case-by-case delay will increase to $225; the “large deposit” exception reason will increase from $5,000 to $5,525, among others.
You might be asking, why are you telling us this in May?
Well, Regulation CC requires that you notify affected customers of these changes to your funds availability policy. Since these changes expedite the availability of funds, you must notify them no later than 30 calendar days after the changes take effect. Thus, you have until July 31st. That said, you do still have the option of notifying them prior to the effective date if you wish. Due to different statement cut-off dates, you may want to start the notification process before the July 1st effective date. Whichever timing option you choose, remember:
A notice may be given in any form as long as it is clear and conspicuous. If the bank gives notice of a change by sending the customer a complete new availability disclosure, the bank must direct the customer to the changed terms in the disclosure by use of a letter or insert, or by highlighting the changed terms in the disclosure.
There is no model language for this notification but something similar to the following could be used:
Effective 7/1/2020, we are increasing the amount we make available for withdrawal by checks not subject to next day availability to $225. In addition, the amount available for withdrawal on exception holds for large deposits and new account holds is increasing to $5,525.
We conducted a Regulation CC Webinar back in February that is available now on-demand. This webinar walks you through Regulation CC compliance and addresses the changes effective July 1st.
Be sure to stay tuned to our blog, as we will be updating the free Regulation CC tools available in the coming months!
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Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!