Study guide
17.2 Initial-Dollar Availability, Ordinary Checks and Policy Disclosures
CRCM Certified Regulatory Compliance Manager Exam
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1 1. CRCM Exam and Study Planning
1.1 CRCM examination, eligibility and study strategy
2 2. Electronic Transfers and Error Intake
2.1 Regulation E: Coverage and Consumer Disclosures 2.2 Regulation E: Error Notices and Unauthorized Transfer Liability 2.3 EFT Error Investigation and Provisional Credit
3 3. EFT Investigations, Remittances and Prepaid Accounts
3.1 Extended Error Rules and Remittance Transfers 3.2 Prepaid accounts and special Regulation E controls 3.3 Truth in Savings: Account Disclosures and APY
4 4. Overdraft Operations and Advertising
4.1 Overdraft Practices, Fees and Advertised Terms
5 5. ECOA Applications and Credit Decisions
5.1 ECOA Coverage, Protected Bases and Application Inquiries 5.2 Age, Spousal Signatures and Joint Credit Intent 5.3 ECOA Action Notices and Specific Reasons
6 6. Valuations and Fair Lending
6.1 Business Credit Notices and Appraisal Delivery 6.2 Fair Lending: Treatment, Effects and Comparative Evidence 6.3 Redlining, Steering and Qualified Self-Tests
7 7. Credit Cards, HELOCs and Open-End Credit
7.1 Credit Cards: Coverage, Disclosures and Ability to Pay 7.2 Credit Card Fees, Payment Allocation and Billing Errors 7.3 HELOCs and general open-end credit
8 8. Closed-End Credit and Mortgage Disclosures
8.1 Closed-End Credit: Disclosures, Finance Charges and APR 8.2 Rescission Timing and Ability-to-Repay Standards 8.3 TRID Integrated Disclosures: Loan Estimate, Closing Disclosure & Fee Tolerances
9 9. Education Loans and Mortgage Insurance
9.1 Private education loan disclosures and cancellation 9.2 Homeowners Protection Act and PMI termination
10 10. HMDA Coverage and Reporting
10.1 HMDA Institutional and Loan Coverage 10.2 HMDA Exclusions, Partial Exemptions and Data Points 10.3 HMDA: Loan Application Register (LAR) Compilation, Demographic Collection & Submission
11 11. Flood Insurance
11.1 Flood Determinations, Notices and Required Coverage 11.2 Flood Contents, Escrow, Private Policies and Force Placement
12 12. CRA Evaluation and Assessment Areas
12.1 CRA Institution Categories and Performance Tests 12.2 Community Development, Ratings and Performance Context 12.3 CRA Assessment Areas and Public File Contents
13 13. CRA Disclosures, Branching and Consumer Protection
13.1 CRA File Deadlines, Notices and Sunshine Agreements 13.2 Interstate banking and branch closing duties 13.3 Unfairness, Deception and Consumer Injury
14 14. UDAAP Controls and Social Media
14.1 Abusiveness and UDAAP Program Controls 14.2 Social media advertising, complaints and records
15 15. BSA Programs, Customers and Currency
15.1 BSA Program Pillars and Independent Testing 15.2 Beneficial Ownership, CIP and Ongoing Due Diligence 15.3 Currency Reports, Aggregation and Exemptions
16 16. Suspicious Activity and Sanctions
16.1 Suspicious Activity Reporting, Confidentiality and Records 16.2 Sanctions Scope, Ownership and Blocking Decisions 16.3 OFAC Reports, Records, Licensing and Screening Controls
17 17. Check Availability and Exception Holds
17.1 Regulation CC Scope, Deposit Days and Next-Day Items 17.2 Initial-Dollar Availability, Ordinary Checks and Policy Disclosures 17.3 Exception Hold Grounds and Reasonable Periods
18 18. Hold Notices and Settlement Services
18.1 Hold Notices, Timing and Consumer Communications 18.2 RESPA Coverage, Referral Payments and Fee Splits 18.3 Permissible Services, Ownership Returns and Marketing Agreements
19 19. Mortgage Servicing
19.1 Escrow, Servicing Errors and Force-Placed Insurance 19.2 Early Intervention, Continuity of Contact and Loss Mitigation
20 20. Consumer Reports and Credit Decisions
20.1 Consumer Reports: Permissible Purpose and Employment Use 20.2 FCRA Adverse Action Notices and Credit Score Disclosures 20.3 Risk-Based Pricing and Furnisher Accuracy Duties
21 21. Furnishing, Medical Information and Identity Theft
21.1 Negative Information Notices and Furnisher Disputes 21.2 Medical information in credit decisions: Regulation FF and V 21.3 Identity Theft Program Scope, Governance and Detection
22 22. Identity Theft and Debt Collection
22.1 Red Flag Responses, Program Updates and Address Validation 22.2 Debt Collector Scope, Calls and Communication Limits 22.3 Electronic Collection Messages and Validation Disputes
23 23. SCRA Protections and MLA Coverage
23.1 SCRA Eligibility and the Six-Percent Interest Cap 23.2 SCRA Foreclosure, Repossession, Leases and Waivers 23.3 MLA Borrowers, Identification and Credit Exemptions
24 24. Military Credit and Consumer Communications
24.1 MAPR, Military Disclosures and Prohibited Credit Terms 24.2 TCPA Calling Technology, Consent and Do-Not-Call Rules 24.3 Telephone Enforcement, TSR Coverage and Commercial Email
25 25. Electronic Consent and Consumer Leasing
25.1 E-SIGN Consent and Consumer Electronic Records 25.2 Consumer Leasing Coverage, Disclosures and Residual Value
26 26. Deposit Insurance and Privacy Notices
26.1 FDIC Insurance: Single, Joint and Trust Ownership 26.2 Retirement, Business and Custodial Insurance; FDIC Signs 26.3 Privacy Notices, Sharing and Opt-Out Opportunities
27 27. Privacy Sharing and Information Security
27.1 Privacy Sharing Exceptions, Account Numbers and Reuse 27.2 Information Security Programs and Incident Investigation 27.3 Customer Incident Notices and Regulatory Notification Clocks
28 28. Authentication and Specialized Data Privacy
28.1 Authentication, access and layered security 28.2 GDPR scope, lawful processing and incident response 28.3 HIPAA and HITECH in bank services
29 29. Insider Lending and Affiliate Definitions
29.1 Regulation O Insider Definitions and Nonpreferential Credit 29.2 Insider Approvals, Lending Limits and Executive Restrictions 29.3 Affiliate Definitions, Covered Transactions and Collateral
30 30. Affiliate Transactions, Appraisals and Originators
30.1 Low-Quality Assets, Market Terms and Affiliate Limits 30.2 Title XI Valuation Thresholds, Exemptions and Credentials 30.3 Valuation Independence, HPML Appraisals and SAFE Registration
31 31. Garnishment and Financial Records
31.1 Federal Benefit Garnishment: Review, Protection and Notice 31.2 Financial Privacy: Government Requests, Certificates and Exceptions 31.3 Regulation S and financial-record reimbursement
32 32. Bank Security and Insurance Sales
32.1 Bank Bribery and Physical Security Programs 32.2 Security Reporting and Retail Nondeposit Investments 32.3 Consumer protection in bank insurance sales
33 33. Securities Activities and Anti-Bribery Rules
33.1 Regulation R and bank brokerage exceptions 33.2 Regulation U purpose credit and margin collateral 33.3 FIRREA civil penalties and foreign bribery risks
34 34. Payment Systems, Child Privacy and Tax Reporting
34.1 Deposit Classification, Reserve Ratios and Debit Interchange 34.2 Internet Gambling Controls, Child Privacy and Email Rules 34.3 IRS information reporting and backup withholding
35 35. Accessible Banking
35.1 ADA Title III and access to banking services
36 36. CMS Governance and Operating Procedures
36.1 Board of Directors & Senior Management Oversight: Responsibilities, Culture & Resources 36.2 The Three Lines of Defense Model in Bank Compliance 36.3 Compliance Policies and Procedures: Development, Approval Cycles & Operationalization
37 37. Compliance Risk Assessment
37.1 Compliance Risk Assessment: Exposure and Control Evidence 37.2 Residual Risk, Specialized Reviews and Event-Driven Updates 37.3 Risk Scoring, Impact Dimensions and Risk Appetite
38 38. Risk Indicators and Compliance Training
38.1 Compliance Indicators, Emerging Risks and Model Limits 38.2 Legal Training Duties and Role-Based Curriculum 38.3 Board Education, Training Administration and Effectiveness
39 39. Monitoring, Testing and Vendor Diligence
39.1 Monitoring, Independent Assurance and Risk-Based Scoping 39.2 Sampling Objectives, Workpapers and Testing Reports 39.3 Third-Party Planning, Diligence and Contract Design
40 40. Vendor Controls and Complaint Management
40.1 Vendor Monitoring, Fintech Controls and Service-Company Notices 40.2 Complaint Intake, Investigation and Root Cause 40.3 Complaint Reporting, Agency Responses and Systemic Redress
41 41. Regulatory Change and Corrective Planning
41.1 Regulatory Surveillance, Impact Assessment and Gap Analysis 41.2 Change Implementation, Validation and Judicial Stays 41.3 Issue Prioritization, Root Cause and Corrective Plan Design
42 42. Restitution and Examination Management
42.1 Remediation Populations, Restitution and Closure Evidence 42.2 Examination Coordination and Consumer Compliance Ratings 42.3 Supervisory Findings, Responses and Enforceable Actions
43 43. Regulatory Reports and Resubmissions
43.1 Regulatory reporting, corrections and examiner updates
17.2 Initial-Dollar Availability, Ordinary Checks and Policy Disclosures
Key Takeaways Explain This Topic AI
Current initial-dollar availability and large-deposit amounts reflect the July 2025 inflation adjustment.
Ordinary checks generally follow second-business-day availability, subject to applicable exceptions.
Funds-availability disclosures must describe the institution’s actual policy rather than merely quote maximum hold periods.
Last updated: October 2026
The Statutory Initial Dollar Amount Rule (§ 229.10(c)(1)(vii))
For all check deposits that do not otherwise qualify for next-day availability under § 229.10, the bank must make up to $275 of the aggregate check deposits available on the next business day following the banking day of deposit.
Inflation Indexing: Originally established at $100 by the EFAA, the statutory amount was increased to $200 by the Dodd-Frank Act and is indexed for inflation every five years under Regulation CC joint rules, currently standing at $275 .
Aggregate Daily Limit: The $275 rule applies in the aggregate across all non-next-day checks deposited by a customer on a single banking day, not on a per-check basis.
Second-Business-Day Availability for Local Checks (12 CFR § 229.12)
All check deposits not qualifying for next-business-day availability are subject to the second-business-day availability schedule under 12 CFR § 229.12:
Unified Local Check Rule: Historically, Regulation CC distinguished between "local checks" (drawn on banks in the same Federal Reserve check processing region, subject to a 2-day schedule) and "non-local checks" (drawn across regions, subject to a 5-day schedule). With check imaging modernization under Check 21 and the consolidation of Federal Reserve check processing into a single national facility in Cleveland, all checks clearing within the United States are now classified as local checks .
Standard Availability: The remainder of funds deposited by check (after releasing the initial $275) must be made available for withdrawal no later than the second business day following the banking day of deposit .
Cash Withdrawal Availability Rules (12 CFR § 229.12(d))
For checks subject to second-business-day availability, Regulation CC provides a specialized sub-schedule for physical cash withdrawals:
On the next business day following deposit, the initial $275 must be available for all withdrawal purposes, including cash.
On the second business day following deposit, the bank must make up to $550 available for cash withdrawals at teller counters or ATMs by 5:00 PM (or the bank's close of business), while the entire remaining balance of the check must be available for non-cash transactions (such as check writing, ACH debits, and bill payments).
The remainder of the deposit must be available for cash withdrawal on the third business day following the banking day of deposit.
Mandatory Disclosures and Policy Notifications
Depository institutions must maintain an active compliance program to ensure accurate, timely disclosure of funds availability policies to all transaction account holders.
Initial Disclosures (12 CFR § 229.17, § 229.18)
Timing: A financial institution must provide a written disclosure describing its specific funds availability policy prior to opening a transaction account.
Remote Openings: If an account is opened by telephone or the permitted written-request process, the disclosure must be mailed or delivered electronically no later than the first business day following the day the account is opened.
Content: Disclosures must clearly detail the bank's availability schedules, cut-off hours, exception hold practices, case-by-case hold policies, and procedures for obtaining immediate credit.
Branch Lobby, ATM & Deposit Slip Notices (12 CFR § 229.18)
Posted Lobby Notices (§ 229.18(b)): The bank must post a conspicuous notice at all locations where retail deposits are accepted (including teller counters, customer service desks, and drive-through lanes) stating the bank's general availability policy.
ATM Notices (§ 229.18(c)): The bank must post or display a conspicuous notice on all proprietary automated teller machines stating that funds deposited at the ATM may not be available for immediate withdrawal.
Preprinted Deposit Slips (§ 229.18(a)): All preprinted deposit slips provided by the bank must incorporate a clear notice stating: "Deposits may not be available for immediate withdrawal."
Change-in-Terms Advance Notification (12 CFR § 229.18(e))
Institutions must implement strict change-management procedures when altering funds availability policies:
Adverse Changes: If the bank modifies its policy to make funds availability more restrictive (e.g., lengthening hold periods, advancing cut-off hours, or transitioning from immediate availability to statutory limits), the bank must provide written notice to all affected account holders at least 30 calendar days prior to the effective date of the change.
Expedited Availability: If the change expedites availability (e.g., eliminating holds or increasing next-day availability thresholds), notice may be provided no later than 30 calendar days after the change is implemented.
Summary of Statutory Availability Schedules
Deposit Instrument / Transfer Type In-Person Required? Payee Account Required? Statutory Availability Deadline Regulatory Citation
Electronic Direct Deposit / Wire Transfer No Yes Next business day following banking day of receipt 12 CFR § 229.10(b)
Cash Deposited to Bank Employee Yes N/A Next business day following banking day of deposit 12 CFR § 229.10(a)(1)
Cash Deposited at Proprietary ATM No N/A Second business day following banking day of deposit 12 CFR § 229.10(a)(2)
U.S. Treasury Check No Yes Next business day following banking day of deposit 12 CFR § 229.10(c)(1)(i)
U.S. Postal Service Money Order Yes Yes Next business day following banking day of deposit (2nd day if ATM) 12 CFR § 229.10(c)(1)(ii)
Federal Reserve / FHLB Check Yes Yes Next business day following banking day of deposit 12 CFR § 229.10(c)(1)(iii)
State or Local Government Check Yes Yes Next business day (must be in-state; special slip if required) 12 CFR § 229.10(c)(1)(iv)
Cashier's, Certified, or Teller's Check Yes Yes Next business day (special slip if required by policy) 12 CFR § 229.10(c)(1)(v)
On-Us Check Yes Yes Next business day following banking day of deposit 12 CFR § 229.10(c)(1)(vi)
Statutory Check Initial Amount No No Next business day (first $275 of aggregate check deposits) 12 CFR § 229.10(c)(1)(vii)