Question:
This is regarding the recent threshold changes to Regulation CC. Since we have same day availability and the amounts are actually in the customers’ favor, do we have to do a change notice to reflect the new funds availability thresholds? Answer: Yes, it would still be required to be updated and provided within 30 days of the change as set out here: (e) Changes in policy. A bank shall send a notice to holders of consumer accounts at least 30 days before implementing a change to the bank's availability policy regarding such accounts, except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation. https://www.ecfr.gov/cgi-bin/text-idx?SID=3637768da342b80a478311cfcb340a34&mc=true&node=se12.3.229_118&rgn=div8 Comments are closed.
|
Archives
March 2020
CategoriesCompliance Alliance offers a comprehensive suite of compliance management solutions.
To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com. |