Compliance Blog

Aug 19, 2011
Categories: Accounts

Regulation CC & Dodd-Frank; The Bay State

Written by Steve Van Beek

The Federal Reserve issued a Consumer Affairs Letter that discusses Reg CC and the $200 change from Dodd-Frank. 

"Section 1086 of the Dodd-Frank Act amended the Expedited Funds Availability Act to require depository institutions to make the first $200 of funds deposited into an account by certain checks available for withdrawal on the business day after the banking day the deposit is received. Previously, depository institutions were required to make the first $100 available on the business day after such a deposit.

The Federal Reserve Board (Board) recently proposed revisions to Regulation CC, including the changes described above. See 76 Fed. Reg. 16862 (Mar. 25, 2011). While Regulation CC has not yet been finalized, supervised institutions will nevertheless be expected to comply with applicable statutory requirements."

The letter is dated August 15.  Which is interesting because the change to $200 became effective July 21, 2011.  

Dodd-Frank was signed on July 21, 2010.  The Reg CC proposal was released March 3, 2011.  I'm still puzzled why the Fed did not propose two separate rules - with one proposal solely implementing the $200 change.

These are the types of headaches that do not get captured in any data on regulatory burden.

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A familiar name has formed an Exploratory Committee for a Senate run in Massachusetts.  (WSJ.com)

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Have a great weekend!  Only two more weeks until football season!  Â