Consumer Compliance Outlook: First Quarter 2010

Compliance Alert

The Board of Governors of the Federal Reserve System (Board) announced amendments to Appendix A of Regulation CC - Routing Number Guide to Next-Day Availability Checks and Local Checks on December 31, 2009.

These amendments reflect the restructuring of the Federal Reserve Banks' check-processing operations. Appendix A of Regulation CC provides a routing symbol guide that helps depository institutions determine the maximum permissible hold periods for most deposited checks. The amendments delete the reference to the head office of the Federal Reserve Bank of Atlanta and reassign the routing symbols currently listed under that office to the head office of the Federal Reserve Bank of Cleveland. Effective February 27, 2010, the Federal Reserve Bank of Cleveland will process checks for the entire country, which will eliminate nonlocal check holds.

Previously, a check was defined as "nonlocal" if the depository bank was not in the same check-processing region as the payor bank based on the banks' respective routing numbers. Checks considered nonlocal before the change will be considered local as of February 27, 2010, and subject to the two business-day funds availability requirement under §229.12(b). Banks1 should update their disclosures and adjust their systems to reflect this change. Additionally, §229.18(e) External Site requires that when a bank changes its availability policy for consumer accounts that expedites the hold for checks, it must send a notice of the change not later than 30 days after the change becomes effective. The announcement is available on the Board's website External Site.