Even More Regulation CC Changes
By: Fran Sponsler, CRCM, CCBCO
Date: 12/3/09
Federal Reserve Board Regulation CC – Funds Availability continues to change. Effective October 17, 2009 and November 14, 2009, the Board of Governors of the Federal Reserve amended the routing number guide to next-day availability checks and local checks in Regulation CC to delete the references to the head offices of the Federal Reserve Bank of Dallas and the Los Angeles branch office of the Federal Reserve Bank of San Francisco. The routing numbers currently listed under those offices are now reassigned to the head office of the Fourth Federal Reserve District known as the Federal Reserve Bank of Cleveland.
The affect of these changes have left just a few check processing regions standing; the Third, Fourth, and Sixth Federal Reserve Districts. However, this is about to change. Effective December 12, 2009, the Third Federal Reserve District – Philadelphia will merge into the Fourth Federal Reserve District – Cleveland; which will then leave only two processing regions, the Fourth Federal Reserve District – Cleveland and the Sixth Federal Reserve District – Atlanta.
What does this mean for your Bank?
Most of the holds that your financial institution invokes on or after December 12, 2009 will likely be a local item hold; unless, the check is drawn on the Sixth Federal Reserve District of Atlanta. A full listing of these routing numbers is located on the Federal Reserve website under Regulations/Regulatory Amendments.
What does your Bank need to do to comply?
Banks will need to update their Regulation CC hold policy and procedures and any staff training materials on how to invoke a hold to ensure funds are being held for the appropriate amount of time. Banks are not required to provide customers with a listing of the updated routing numbers.
It is anticipated that sometime during the first quarter of 2010, the remaining two check processing regions will be merged, which will result in all deposited checks being considered local items when placing either a case-by-case hold or an exception hold. At that time, financial institutions will have to change their policies and disclosures to eliminate all references to non-local checks.
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