Regulation CC: Funds Availability

Ok, let’s just get this out of the way:  Reg CC stinks.  It makes my head hurt and makes me say impolite words.  Please tell me I’m not the only mild-mannered compliance professional who becomes… shall we say… unpolished… when trying to comply with this rule!

This rule applies to deposits of funds into your institution.  Technology has evolved massively since Reg CC was first written, and its patchwork of amendments have been a challenge to follow – not that it was easy to follow in the first place. But!  It is super important!  Not only does it govern how you place holds on deposited funds, but it also mandates disclosures and dictates rules for ATM deposits, mobile deposits, electronic check collection and substitute checks under “Check 21”.  It simply cannot be ignored because it is challenging.

If your institution accepts deposits, you need to know this information well.  This is relevant material for everyone who touches deposits in your institution. 

Topics covered in this session

• Subpart A:
• Definitions of everything you need to know– from (a) to (hhh)!

• 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 

Who Should Attend:

• Compliance officers
• Operations officers
• Teller department managers
• Tellers
• Back-room operations staff
• Auditors