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Regulation CC stipulates four types of holds that a bank may place on a check deposit at its discretion. Each has its own qualifications and it is legal for the bank to place any type where the requirements are met, although bank policy may instruct that the type of hold placed be the one that holds the most funds the longest that can be applied legally.
The Expedited Funds Availability Act (EFAA) of 1987, implemented by Regulation CC, defines when standard holds and exception holds can be placed on checks deposited to checking accounts, and the maximum length of time the money can be held. A bank's hold policy can be less stringent than the guidelines provided, but it cannot exceed the guidelines.
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Create a comparison chart: Current, case-by-case approach vs. policy-driven approach. Highlight the benefits in terms of fairness, legal compliance, time savings, and employee satisfaction.
The Federal Reserve’s top banking regulator Michael Barr will step down from his position in February, saying that "the risk of a dispute over the position could be a distraction from our mission."
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