#Current reg cc check available update#
In fact, some institutions are choosing to update disclosures and provide change notices earlier in the year, at the same time as other routine service charge change notices. There is nothing that prohibits you from implementing these changes prior to July 1. Provide your customers with notice of the change – When a change in policy expedites the consumer’s ability to use funds, the regulation requires disclosure of the change within 30 days after implementation.Update your hold notices – Hold notice forms that include the amounts of available funds should be updated to reflect the increased amounts that will be available.If you make disclosures available on your website, be sure to update those as well. Update your initial disclosure – For all hold types disclosed, your financial institution should update initial account disclosures to reflect the increases in the amounts required to be made available.What should you do to ensure you are ready for the July compliance deadline? The adjustments will be based on increases in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) and rounded to the nearest multiple of $25. The final rule also established a timetable for future adjustments with the next adjustment expected on July 1, 2025, and continuing every fifth year thereafter. The amount that must be available in this instance increases from $400 to $450. The last dollar adjustment for check holds is to the amount required to be released for payment of cash or other similar means if your institution discloses and extends the amount available for withdrawal by one business day. Are you prepared?īeginning July 1, 2020, your financial institution will be required to provide $225 for next day availability for all instances where it was required to provide a minimum of $100 ($200). In addition, the $5,000 availability requirements for holds on new accounts, large deposits, and repeat overdrafts will increase to $5,525.
However, changes to the amounts required to be made available are now going into effect this year, including revisions to the amounts that must be available under certain exception holds. These changes were made solely within the act but were not codified in the regulation. Other requirements from the regulation, such as model hold notices and the elimination of the word “non-local,” still seem to be in “proposal” state without any clear guidance from the Federal Reserve or Consumer Financial Protection Bureau regarding when these changes will be finalized, if ever.īack in 2011, financial institutions were required to increase, from $100 to $200, the amount available to consumers the next business day after the banking day that the applicable check deposits were made. It has been nine years since the Dodd-Frank Act required the first set of adjustments to the hold amounts in Regulation CC.
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