2020 Reg CC changes

In 2010, the Dodd-Frank Act amended the Expedited Funds Availability (EFA) Act requiring regular inflation adjustments to certain hold thresholds triggered every time there is an adjustment for inflation starting on July 1, 2020. The Consumer Financial Protection Bureau issued a 63-page final rule on June 24, 2019 that amended some parts of Regulation CC relating to check holds and funds availability and included customer notification requirements. 

Inflation adjustments for holds and funds availability:

  • $200 increases to $225 – this is the amount used on case-by-case holds (Note: the $200 amount is still referred to as $100 in Reg CC). 
  • $5,000 increases to $5,525 – this is the amount used on certain special exception holds, such as large deposit holds, new account holds and repeatedly overdrawn holds.  
  • $400 increases to $450 - rarely used rule that permits financial institutions to extend holds by one business day when a deposit is withdrawn by cash or similar means.
  • Civil liability amounts - $1,000 increases to $1,100 and $500,000 increases to $552,500. 

Customer notifications:

  • While the inflation amount changes can be implemented prior to July 1, banks must be aware of the requirement to notify existing customers about the change within 30 calendar days following implementation. Assuming the change is implemented on July 1, customers must be notified by July 31.

Meet The Rehmann Team

Start typing a name ...
Searching for "{{nameQuery}}"...
Start typing an experience ...
Searching for "{{experienceQuery}}"...
Start typing a location ...
Searching for "{{locationQuery}}"...
Or view a list of team members

get rehmann expertise to drive your business in your inbox every week