Compliance Q&A: Reg CC Considerations

Question: Do Reg CC exception holds apply to check deposits drawn on foreign banks?

Answer: If the check is actually drawn on a foreign bank not located in the US, it would not be considered a “check” covered by Reg. CC. Therefore, would not be applicable to Reg CC and you can put a hold on it for as long as it takes to clear. It’d mainly be a policy issue. Whatever time you feel is reasonable based on the surrounding circumstances. 


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