All in Regulation CC

Summary of Reg CC Changes for July 2020

Adam Witmer
Regulation CC

In this article, we provide a summary of the Reg CC changes that financial institutions must comply with by July 1, 2020. In addition to the summary, this article provides a 10-step implementation plan for complying with the recent changes. Now is the time to get started implementing the new Reg CC rules, and it is our hope that this article can assist you in a successful implementation of the new rules.

Using the Repeated Overdrafts Hold Reason

Using the Repeated Overdrafts Hold Reason

Adam Witmer
Regulation CC

In this Compliance Clip (video), Adam discuses the two different options for using the “repeated overdrafts” hold reason and also discusses how the new inflation adjustments will change this reason.

For those interested in learning more about how the June 2019 Reg CC amendments will impact the funds availability rules, be sure to check out our Reg CC Training for Tellers in our store at www.compliancecohort.com/reg-cc-training-for-tellers.

5 Reasons Why the New Reg CC Amendments are Terrible!

5 Reasons Why the New Reg CC Amendments are Terrible!

Adam Witmer
Regulation CC

In this Compliance Clip (video), Adam explains 5 reasons why the new Regulation CC amendments are terrible for financial institutions. Okay, they aren’t really “terrible,” but they definitely aren’t ideal or as good as they could have been. As you will see in this video, there are a number of challenges this new rule creates, so it will be imperative for financial institutions to quickly create a strategy for implementing these rules. Adam concludes by providing a brief overview of a solution to help you easily navigate the challenges associated with this new rule - our new training program on the Regulation CC amendments, which can be found at https://www.compliancecohort.com/video-webinar-regulation-cc-june-2019-amendments

CFPB Releases Regulation CC Amendments (Video)

CFPB Releases Regulation CC Amendments (Video)

Adam Witmer
Regulation CC, Regulatory Update

In this Compliance Clip (video) Adam provides an overview of the Regulation CC amendments that were released on June 24, 2019. While these amendments are really just a small part of what is yet to come (probably very soon), these amendments will cause a number of challenges for financial institutions. First of all, the $200 and $5,000 thresholds have been increased for inflation - and will continue to be increased for inflation on a regular basis. Secondly, each time the threshold is increased, a change of terms notice is going to need to be delivered to applicable customers. Finally, there are a few other minor changes in this new final rule, which Adam explains in this video.

Reg CC Holds on Savings Accounts

Reg CC Holds on Savings Accounts

Adam Witmer
Regulation CC

Adam uses this Compliance Clip (video) to explain how Regulation CC holds apply to savings accounts. Specifically, Adam answers the question on how long a next day item (like a cashier’s check or treasury check) can be delayed on a savings account. After a quick deep dive into the applicability of Regulation CC, Adam explains his answer in the geeky detail that only he can deliver in such an exciting manner.

Special Exception Hold Reasonable Cause Examples

Adam Witmer
Regulation CC

In auditing check holds over the years, I have often found violations of of Regulation CC.  These violations result from a number of things, such as incorrectly calculating the amount of a hold or incorrectly choosing the wrong date to make funds available.  Often times, there isn’t a pattern or practices as to why these violations occur - other than a lack of training - though I have noticed a trend of violations relating to one specific special exception hold reason: The reasonable cause to doubt collectibility.

Two Comments Due Next Week

Adam Witmer
Regulatory Update, Regulation CC

Two sets of comments are due next week.

First, Tuesday, February 5 marks the last day to comment regarding the proposal to increase the appraisal threshold for residential real estate transactions from $250,000 to $400,000.  The proposed rule provides thirteen questions for which the agencies are seeking comment.

Secondly, comments regarding the Regulation CC proposal must be in by Friday, February 8, 2019.  This request for comment does two things as the proposal would first implement new changes to the Expedited Funds Availability Act and also provides an additional opportunity for public comment on the 2011 funds availability proposal that was never finalized.

Fed & CFPB Reopen Comments & Proposal for Reg CC Proposed Rule

Adam Witmer
Regulation CC, Regulatory Update

On 11/20/18, the CFPB and Federal Reserve jointly issued a 58 page “proposed rule and reopening of comment period for existing proposed rule” for Regulation CC.  This request for comment does two things as the proposal would first implement new changes to the Expedited Funds Availability Act and also provides an additional opportunity for public comment on the 2011 funds availability proposal that was never finalized.

Comments must be received within 60 days after the date of publication to the Federal Register.

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