Compliance Alliance Question of the Week
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?
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.
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