Question:
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?
Answer:
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.
https://www.ecfr.gov/cgi-bin/text-idx?SID=3637768da342b80a478311cfcb340a34&mc=true&node=se12.3.229_118&rgn=div8
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