The Compliance 911 Show

In episode 64 of the Compliance 911 podcast, hosts Len Suzio and Dean Stockford discuss the intricacies of Reg. CC, a regulation that deals with funds availability. Dean emphasizes the importance of understanding the definitions within regulations as the same word or phrase might carry different meanings in different contexts. He goes on to explain that Reg. CC was implemented to enforce the provisions of the Expedited Funds Availability Act of 1987, which set the rules for when a bank had to make deposited funds available to depositors. The regulation is highly technical and mandates strict timing provisions based on factors such as the nature of the item deposited, where and to whom the deposit was made, and the bank's funds availability policy.

Dean delves deeper into the timing specifics, noting that funds availability begins at the start of a “business day.” He lists types of deposits that must be made available on the next business day, such as cash, electronic payments, U.S. Treasury checks, and certain other checks. Len, intrigued by the strictness of the rules, inquires about any potential exceptions. Dean highlights that banks can place Exception Holds, also known as Safeguard Holds, to mitigate risks. These holds allow financial institutions to manage fraud, but they must adhere to specific protocols, including providing customers with written notices detailing reasons for the extended hold. The episode concludes with Dean urging listeners to thoroughly understand Reg. CC.

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