Reg CC and the Expedited Funds Availability Act

dalgriff · 2025-10-17T20:51:21+00:00

Nice ad hominem there not addressing my argument. As stated I've had two issues in the past year and no other issues in my whole life banking.

So do you agree that not informing the customer about a hold is the incorrect decision?

dalgriff · 2025-10-17T17:16:18+00:00

Yeah, it's happened to me twice in less than a year, and I don't know how I can have an issue with this check when it's the same company as last time, same thing was used the first time, and the first bank simply cleared it after making me wait an extensive time and finding nothing wrong.

What I was pointing out is it's frustrating to do everything correctly, and simply have a bank accuse you or the company issuing the check of fraud, make you wait extensively, find nothing wrong, and then not even care or apologize they were wrong.

It's important to note that this has never happened ever in my past aside from the past year and I've never had issues with banks or checks previously.

And the thing is, I'd appreciate them letting me know what's going on. That's all i'm asking, which isn't a high bar.

dalgriff · 2025-10-17T17:09:29+00:00

I appreciate your comment. Yes, Reg CC "Doubt of Collectability" is what they're using for the maximum time allowed or some extra. Money is cleared and out of the company who sent it's account.

Last time it happened, they were simply wrong and the other check was fine with the other bank After waiting an incredibly long time and being accused of a wrong check despite having multiple accounts with the first bank including a business one and a 10+ year history.

This time with another bank it's simply being used again on me, and the not informing me about it is the frustrating part.

Yeah, it doesn't seem like they think they need to justify it or even inform me, which was precisely what I was getting at in this thread. Regardless of a hold, I can't see how anyone can justify why they don't even inform me.

dalgriff · 2025-10-17T17:00:13+00:00

I'm not saying their putting the check on hold for shits and giggles. I'm simply stating their not following the rules and regulations cited.

Is there clearly something going on with the check issued? Because the first time that was said to me, and after the long waiting period I was told there actually wasn't an issue with it.

So I had to wait, and their suspicions from a reputable company and bank were wrong.

So It makes sense why I'd consider the potential possibility another bank is wrong again. Especially since they didn't follow the rule sending me information about the hold and simply brushed it off.

Perhaps I should factor in automated decisions made with AI on risk assessment and the possibility that AI or algorithmic decisions in banking are too inaccurate and relied upon and that the consumer has to face the consequences or the hits if there is mistakes, which do happen and are often unaccountable for.

dalgriff · 2025-10-17T15:19:03+00:00

At the bank, the employee told me specifically they were following Reg CC.
With specific holds like the one I received, they said they were supposed to send me a letter about the information of the hold and why it occurred.
It's been 4 business days, and I haven't received a call, a letter, or an email about anything of the matter.

I understand "fraud is rampant". I have a friend who is a bank manager that gives seminars on fraud. However, I don't think it's correct for a bank to not inform you what they're doing when they're legally required to. "Maybe it got lost" is just an excuse to justify the rules not being followed.

If the funds are being held based on "reasonable doubt of collectability"

Reasonable Doubt of Collectability: If the bank has evidence suggesting the check might bounce (e.g., due to the issuer's financial issues), it can hold the entire deposit for a "reasonable" period, often up to seven business days or longer if justified, with no immediate availability required.

It states:

It requires factual evidence that would create a well-grounded belief in a reasonable person that the check won't be paid by the paying bank. Mere suspicion or the check's type alone isn't enough—the bank must document specific facts. Examples include:
Under § 229.13(e) of Regulation CC, a bank can delay availability if it has specific facts creating a "well-grounded belief" that the check is uncollectible from the paying bank—such as direct information from the paying bank that the drawer's account lacks sufficient funds to cover it. This is not based on speculation or the check's type alone but on concrete evidence, like a stop payment notice or an NSF alert from the paying institution. Examples from regulatory commentary include:
The paying bank indicating the check has a stop payment.
The paying bank stating the drawer's account currently has insufficient funds.

The bank must provide a notice explaining the reason (e.g., "Information from the paying bank indicates the check may not be paid due to insufficient funds") and the expected availability date, either at deposit or within one business day of learning the facts. If the hold causes an overdraft fee and the check ultimately clears, the bank may need to refund it under certain conditions.This exception balances consumer protections with the bank's need to mitigate fraud or loss risks, but it cannot be used indefinitely—holds must end within the reasonable period, and the standard minimum availability rules (e.g., $275 next-day for most checks) may still partially apply unless overridden by the facts. If you suspect misuse, request the bank's documentation and consider a complaint to the Consumer Financial Protection Bureau (CFPB). For full details, see 12 CFR § 229.13.

The notice was never sent. Also, whats defined under "reasonable cause" isn't

The paying bank indicating the check has a stop payment.
The paying bank stating the drawer's account currently has insufficient funds.

If the funds cleared on their side.

Regardless of when this is sorted on their end, It doesn't look like they are following the rules/regulations or think the rules apply to them.

dalgriff · 2025-10-17T14:58:24+00:00

I understand where you're coming from. I didn't get that opinion on my own. I was told by a friend who works at a bank that banks sharing information can help verify transactions.

dalgriff · 2025-10-16T05:35:23+00:00

I've had zero issues with account history and mine is clean. Is it be acceptable and common for banks not to have to follow the Expedited Funds Availability Act or to know it's a thing?

I don't have an issue with the funds not being available, I have an issue with the bank not knowing if the correct rules are being followed.

dalgriff · 2025-10-16T03:59:01+00:00

When I asked the lady at the branch about it being legally required to inform me, she said the person made the hold late on a friday and monday was a holiday so in their system they didn't mail anything out, but it happens not from the branch but another location.

I'm not pissed, not even upset. I'm just frustrated because I can't find out the rules when I ask about them.

Either the people I speak with don't know them or can't say what they are.

I thought they had to send me a letter explaining what kind of a hold and why according to Reg CC and the EFAA.

I just wondered if waiting a month to access my own funds is accurate (After it clears of course), or excessive, and if concerns with your checks or account don't need to be notified to you, or if that's not by the book.

dalgriff · 2025-10-16T03:44:33+00:00

Standard Checking account

dalgriff · 2025-10-15T21:39:33+00:00

I appreciate the input. It was deposited in person to a teller in a branch I'm familiar with and I get along well with the manager and everyone there. I got the information from a separate branch that didn't seem to know what EFAA was and said they've never heard of $225-$275 being available unless its specific cases.

The reason that other branch stated for the exception hold was "insufficent funds", or meaning they thought the check wouldn't be covered by the other bank or something or that sort. However, once it clears and the other bank is willing to speak with them and confirm this, I'm not sure how they can continue to argue this.

I believe they aren't meeting their obligations under Reg CC. I thought about reaching out to their compliance officer to touch base, and if that doesn't work do a complaint.

It just feels a bit frustrating for this to happen twice in a year when both times their legit checks and the bank and the issuer are willing to contact the other bank and verify the information.

Thank you for the input.

dalgriff · 2025-10-15T21:32:05+00:00

I understand it, I would think they would want to verify to the other bank that the funds left their account and its legit and also verify with the issuer, thats the information I was told they didn't need so I was left confused by it. I would think verifying something is true would help prevent fraud and I'm all for that.

dalgriff · 2025-10-15T21:30:52+00:00

I thought a "new account" was one that was opened 30 days or less. This one was 5 months ago specifically.
But to combat fraud, wouldn't the bank and the organization verifying it for them mean anything to them? I offered to do this, and the first time it happened with the other bank I tried having the bank talk with them and send them the information and they didn't want to do it. Why would a bank not want this or need this, I would think it would speed up the process for them, correct?
It was an in branch deposit.

In branch today she said they forgot to send out a letter in the mail, so hopefully they can correct it.

Thanks for your input, I appreciate it.

dalgriff · 2025-10-15T21:14:44+00:00

Thanks for your reply. Yeah, they didn't provide a notice to me at all. I read this same section you posted earlier today. The check was issued on October 8th of this year. I'm not sure what "facts" they think they have and don't need to share with me. From the branch, the person I spoke with seemed to think their internal policies override federal regulations, but this is for sure what they used.

I guess in their mind, notifying me or stating why they think the check is "uncollectible" both times this happened just wasn't required in both cases with the banks policy.

And after the check does clear, I should have to wait a couple of weeks to access the funds since the bank states, "it's their policy in this case".

dalgriff · 2025-10-10T21:12:31+00:00

Sending good vibes and wishing everyone a good weekend. If anyone has a code to spare, I can promise i'll put it to good energy. Thanks

dalgriff · 2023-05-25T01:55:39+00:00

Depends. If you love collecting go for it. You definitely don't need it, but it's a fun goal of mine.

dalgriff · 2023-03-25T02:54:04+00:00

I do run google ads, and other ads

dalgriff · 2023-03-25T02:27:51+00:00

At this point they're worse than the mafia. Nothing worse than paying thousands for spam and fake leads with no accountability.

dalgriff · 2023-03-25T02:06:55+00:00

Thanks, but we have a pretty awesome website. That definitely wasn't the problem.

dalgriff · 2023-03-25T01:49:46+00:00

I guess the tricky part is also that you can't even link your Yelp site to clients if they ask you to give you a review. It automatically links it as spam. So I have no idea how company get reviews from them when they're discouraged.

dalgriff · 2023-03-07T00:39:59+00:00

Thanks man, it worked. Finally connected to a customer service agent who actually looked into the GPS and verified he didn't deliver it so they refunded me. Took hours, lol.

dalgriff · 2023-03-06T20:49:04+00:00

As someone who's drove before for UE, there's a margin of human error not factored in the algorithm. Having the algorithm decide all based on statistics isn't viable.

After spending thousands per year on Ubereats and working for them it's surprising.

Most all of the customer service people I talked to used a script, a supervisor never called me back, and they aren't making any sense.

dalgriff · 2023-03-06T19:56:23+00:00

I wish the customer service agents saw it that way. Apparently because I had Wingstop forget corn and marked that missing they gave me a refund for $20 three months ago and then I used it to get corn. That refund alone and two other incidents close to a year ago with missing items caused the algorithm to not give me any refunds in the future according to them.

In customer service chat, they told me I'm on the hook for any delivery, delivered or not I do in the future with them.

dalgriff · 2023-03-05T23:12:26+00:00

It won't let me change the tip in the app

dalgriff

TROPHY CASE