Membership Development Team
Bankers Alliance
P. O. Box 162407
Austin, TX 78716
Phone:  (888) 353-3933
Email
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An expertly-staffed hotline, federal regulatory tools, policies and procedures, and unlimited reviews for small-to-medium community banks across the U.S. — the only all-inclusive banking compliance advisory. C/A’s nearly 1700 products and tools support 48 separate bank compliance areas –an unlimited-access Bank Compliance Library – conforms to the most recently published federal banking rules and regulations. Whether you are building institutional exam-readiness or a bank compliance program, C/A has all the resources, access, and availability for one membership subscription. Co-owned by the Virginia Bankers Association and 28 other state bankers associations across the country. Contact C/A’s Membership Development Team at (888) 353-3933 or at: info@compliancealliance.com. To learn more about C/A’s new Virtual Compliance Officer service or call (833) 683-0701.

Compliance Alliance Featured Q&A

Question:

Our bank is planning on providing immediate (same-day) availability for certain deposits that were previously only subject to (and disclosed as) next-day availability. When would we need to send notice of this change to our customers?   

Answer:

Under Regulation CC’s 12 CFR 229.18(e), a bank is usually obligated to send notice to its customers (more precisely, its “holders of consumer accounts”) at least 30 days before implementing a change to the bank’s funds availability policy that would affect such accounts. 

However, that same section of the rule states that if the change to the policy expedites the availability of funds – such as an update to grant same-day availability to certain deposits that were earlier restricted to only next-day availability – then notice of that change may be disclosed “not later than 30 days after the implementation.” 

Note, though, that the bank certainly isn’t precluded from still providing advanced notice even in these cases, if they so choose, as a matter of customer courtesy or transparency (for example).

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