Deposit Compliance Series: Reg CC

Reg CC is a confusing mess – the Cussing and Cursing regulation.  Reg CC all about the Availability of Funds and Collection of Checks.  What does that mean?

At one time, financial institutions held newly deposited funds for as long as they liked, to ensure they received the money before releasing it to the depositor.  In theory, that was great, but abuses prevailed.  Customers didn’t know when their money was actually theirs to use, and Congress stepped in. When that happened back in 1987, checks were still physically transported from one processing region to another, so a whole schedule was needed to establish reasonable collection times.  Fast forward a few decades, and everything is different.  The days of non-local checks are long gone, and deposits can now be processed in seconds, not days.  Not only that, but funds can be deposited every which way.  Who would have ever thought we’d be taking pictures of a check with a phone, or zapping funds with an app for that!  Not Congress in 1987, that’s for sure. Change is good, and Reg CC has (kind of) attempted to keep up, although it hasn’t been cleaned up along the way. Old, outdated and irrelevant content is still there, mucking up the works and making things confusing. You need to know what can be ignored, and what demands crystal-clear understanding.

 Topics covered in this course

• Subpart A:
• Definitions of everything you need to know

• Subpart B:
• Next-day availability
• Availability schedule (what is left of it)
• Case-by-case holds
• Exception holds
• New Account holds
• Disclosure requirements: what, when, where, and how

• Subpart C:
• Collection of checks
• Electronic checks
• Mobile deposits!
• Responsibilities of paying and returning banks

• Subpart D:
• Substitute Checks
• Disclosure requirements under Check 21

• Appendices:
• What is garbage and what matters

Interested in more Deposit Compliance topics? Check out our other courses on Regs D/DD and Reg E!