Check Hold Inflation Adjustments

Inflation adjustments for Regulation CC – Availability of Funds and Collection of Checks will be effective on July 1, 2025. These adjustments will be applicable for the next five years, at which time a new schedule may be implemented.

The adjustments will require financial institutions to update their disclosures and systems to reflect the new amounts.

The adjustments include:

• Minimum amount not subject to next-day availability requirements (12 CFR 229.10(c)(1)(vii)) $275 (from $225)
• Second-day availability (12 CFR 229.12(d)) $550 (from $450)
• New account exception (12 CFR 229.13(a)(1)(ii)) $6,725 (from $5,525)
• Large deposit exception (12 CFR 229.13(b)) $6,725 (from $5,525)
• Repeated overdraft exception (12 CFR 229.13(d)(2)) $6,725 (from $5,525)

The inflation adjustments also increase the civil liability to not less than $125 nor greater than $1,350; and in the event of a class action, $672,950.

I visited with one of our compliance auditors, Holly Wilson, who completes Regulation CC audits for our bank and credit union clients and asked her where she sees financial institutions have the most exceptions. She said that there is often a lot of confusion regarding the availability of certain checks as defined in (12 CFR 229.10(c)). Checks drawn on the Treasury of the United States and Cashier’s Checks are among the most common types of checks that can cause confusion for financial institutions, and they both require funds to be available on the next business day.

When placing a Large Deposit or New Account exception hold on these types of checks in amounts over $5,525, the first $5,525 must be made available not later than the business day after the banking day on which the funds were deposited.

If you would like to ensure your financial institution meets Regulation CC’s requirements with confidence, contact us. Our experienced auditors are fully trained and up to date on Regulation CC and are ready to deliver a fast, thorough compliance review tailored to your institution.

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