WorkflowDeposit Operations & Account Servicing

Reg CC Exception Holds

Reg CC exception holds decided one deposit at a time: the exception with its sources, every business day counted, and the hold notice drafted from the same dates

Every exception hold applied the same way, with the right dates on the notice.

See one case, screen by screen ↓
demo96%of 500 comparable large deposits got the same hold as Marisol Ferrante's, shown beside her deposit before anyone decided
demo6depositsof 92 flagged on one morning kept at normal availability, because Regulation CC does not allow the hold, each with the rule cited
demo99.8%of hold notices sent on time from October 1 to 13, 561 of 562
target100%of reasonable-cause holds carry the facts behind them and their sources
In short

What is Reg CC Exception Holds?

Reg CC Exception Holds is software for deposit operations teams that decide Regulation CC exception holds on check deposits. Six agents read each flagged deposit, pick the exception that applies or refuse one the rule does not allow, write the facts with their sources, count the business days past weekends and holidays, compare the decision with the bank's own past holds, and draft the hold notice. A specialist approves as the maker and a second specialist checks before the hold is placed and the notice is sent.

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Updated

The problem

Why Reg CC exception holds become exam findings

When a check deposit meets one of Regulation CC's exceptions (a new account, a large deposit over $6,725, a redeposited check, repeated overdrafts, reasonable cause to doubt collectibility, or emergency conditions), the bank may hold it past the normal schedule. But only for a reasonable period, only with a notice that states the amount, the reason and the date, and only if the policy is applied the same way to everyone. Today a teller or a deposit operations specialist picks the reason from a fixed list in the teller or core system, sometimes with a free-text "Other", counts business days by hand around weekends, Federal Reserve holidays and the channel's cutoff, and types the notice.

A holiday missed puts the wrong date on the notice. A redeposit returned only for a missing indorsement is a hold the rule does not allow. A reasonable-cause hold with no facts behind it, such as a teller's sense that a customer seemed rushed, fails an exam, and the same deposit held at one branch and released at another is a fair-treatment question. The amounts changed on July 1, 2025, and forms and parameters still carrying $5,525 or $225 were left behind. Reg CC Exception Holds puts six agents in front of that work, so the specialist starts from the exception proven, the dates counted and the notice drafted.

typical$6,725the large-deposit, new-account and repeated-overdraft amount since July 1, 2025, up from $5,525
typical$1,000the most a court can add in an individual action, on top of actual damages, when a bank fails to follow the rule (12 CFR 229.21(a))
estimated1,400a monthexception holds at a $3.4 billion community bank, each with its own notice clock
Where a specialist's minutes on one exception hold goestimated
By hand24 minutes
With the solution6 minutes
  • Reading the deposit, the check image and the account facts4 → 1 min
  • Picking the exception and writing the reason5 → 1 min
  • Counting business days around holidays and cutoffs4 → 1 min
  • Typing the hold notice and checking its dates6 → 1 min
  • The second specialist's check5 → 2 min

Estimated split of a deposit operations specialist's minutes on one exception hold, by hand and with the agents, from the flagged deposit to the notice sent. Our estimate, kept modest; the after column adds up to the 6 minutes a hold takes to decide in the working solution.

How it works

How one flagged deposit moves

Six agents pick the exception, prove it, count the business days and draft the notice; a specialist approves and a second specialist checks.

What comes in
What it readsAbout 1,400 exception holds a month · deposits, images, account history, rules, templates
Agents at work
Intake agentdeposit, cutoff, day's total
Then
Hold agentthe exception and its facts
Date agentbusiness days, holidays
Then
Consistency agent500 comparable deposits
Notice agentthe notice as it prints
Then
Release agentearly release, extension
A person decides
A deposit operations specialist approves as maker; a second specialist checksbelow 0.85 confidence, the specialist picks the exception
What comes out
Hold placed, right dates
Notice sent the same day
Audit trail and examiner pack
One case, step by step

One large deposit hold, from a mobile deposit after Columbus Day to the notice sent

Tessaly Community Bank, Wednesday, October 14, 2026. Monday was Columbus Day, so Tuesday carried two days of deposits. Marisol Ferrante, a customer since June 2021, deposited one $9,850.00 check by mobile on Tuesday at 6:42 PM: a trade-in payoff from Halvorsen Motor Group LLC. Here is her hold, and the rest of the morning, screen by screen in the working solution.

  1. 016:15 AM

    Two days of deposits read before the team arrives

    Intake agent

    Overnight the intake agent read 14,860 check deposits from item processing, mobile and ATM capture and the core; 92 met a Regulation CC exception. The agents propose 86 holds and keep 6 at normal availability because the rule does not allow the hold. The brief says it in sentences, each with one button, beside the notice clock: 38 sent or closed, 11 with the checker, 43 to decide.

    Notices for Tuesday's deposits are due by 5:00 PM today

  2. 029:14 AM

    One deposit: the check, the exception and a strip of business days

    Janelle Okoro · Deposit Operations Specialist

    Janelle opens Marisol's deposit. On the left, check 20417 with five findings pinned to it: the amounts agree at $9,850.00, the payee matches, the MICR line read, it is dated October 10, 2026, and there is no sign of alteration. The hold agent picks the large-deposit exception, 12 CFR 229.13(b), at 0.97 against a 0.85 floor. The date agent lays the deposit on the calendar: $275.00 on Wednesday, October 14, $6,450.00 on Thursday, October 15, and the $3,125.00 above $6,725 on Thursday, October 22, with the weekends and Columbus Day hatched out.

    Proposed: hold $3,125.00 until Thursday, October 22 · large deposit · notice by 5:00 PM today

  3. 03One click

    Would we do this for everyone?

    Consistency agent

    Before Janelle decides, the consistency agent shows how Tessaly decided its 500 most recent comparable deposits: large-deposit cases of $8,000 to $12,000 on consumer accounts 2 to 7 years old, from a one-off drawer, January 5 to October 13, 2026. The bank held 480 of them. The 20 it released each carry a reason code: the drawer confirmed with the paying bank by phone (9), a customer relationship the branch manager attested (6), and checks drawn on Tessaly flagged in error (5).

    Never used: names, ages or any protected characteristic

  4. 04Before the decision

    The hold notice as it will print, from the same dates

    Notice agent

    The notice agent drafts the notice from approved template v4.2: account XXXXXX4417, deposited October 13, 2026, $9,850.00 deposited, $3,125.00 on hold, available on Thursday, October 22, 2026, and the rest on October 14 and 15. A checklist confirms the six items 12 CFR 229.13(g) requires, the timing, plain language at grade 7 and that nothing hints at a fraud review. Because the notice and the strip come from the same slices, they cannot disagree.

    Why: The checks you deposited on this day total more than $6,725.

  5. 059:24 to 9:26 AM

    Approved by the maker, checked by a second specialist

    Curtis Fenwick · Deposit Operations Checker

    Janelle approves the hold as the maker at 9:24 AM; she cannot check her own decision. Curtis, a second specialist, works through a five-point checklist and approves at 9:26 AM. Only then does the hold go to the core and the notice to Marisol, by online banking at once and on paper in the 5:00 PM mail batch.

    Hold placed on the core (EX-LD, release 10/22/2026) and the notice sent by online banking at 9:26 AM

  6. 06The same morning

    A Treasury check a teller wanted held, and why an impression is not a reason

    Hold agent

    Harold Quist deposited a $1,912.40 U.S. Treasury check at the Harlow Street branch, and the teller asked for a reasonable-cause hold with the note "customer seemed rushed." The agents propose no hold: reasonable cause must rest on facts, and a customer who seemed rushed is an impression, not a fact. The check has no return history and no image findings, so as a next-day item the money is available Wednesday, October 14. A specialist confirms and the branch gets a plain note. A specialist who has facts can still place a hold, and it goes to the checker.

    An impression is not reasonable cause · 12 CFR 229.13(e)

  7. 07Reasonable cause

    A reasonable cause hold written as facts, each with its source

    Hold agent

    Lyle Brandt deposited a $2,480.00 check from Corbin Tile & Stone LLC at the Eastgate ATM. The hold agent states the facts: two checks from the same account came back unpaid for insufficient funds on October 2 and October 8, and the payee line is written over a lighter, earlier name, pinned on the image at 0.82 against a 0.80 floor. Each fact opens its source, the return file or the check image. Tessaly gave the same hold to 71% of 214 comparable deposits.

    Fraud case management told · internal only

  8. 08Collected funds

    38 early releases in one approval, with a checker

    Release agent

    The release agent watches presentment and returns. Thirty-eight holds deposited October 1 to 8, $286,940.00 in all, are collected under the bank's rule CF-1, two business days after presentment. Janelle releases them as the maker and a checker posts them. The agent explains the three it left out: Silas Redfield's $8,125.00 (a notice of nonpayment), Tallgrass Roofing Co.'s $16,400.00 (a fraud alert) and Vera Holloway's $2,310.00 (the window has not passed).

  9. 094:12 PM the day before

    A stolen-check report extends a hold, with a new notice the same day

    Release agent

    Pruitt Lawn & Landscape LLC deposited a $7,940.00 check from Ostrander Property Group at the Granger Square branch, with $1,215.00 on a large-deposit hold. Brookhollow Bank's interbank notice says the drawer reported check 40118 stolen. The agents propose reasonable cause on $7,665.00 to Thursday, October 22, with $275.00 already available, cite the notice, and draft the changed-hold notice, due by 5:00 PM. The fraud case stays internal.

    We have changed the hold on your deposit

  10. 10At the branch

    The words for the customer, and a way to ask

    Owen Laird · Branch Manager, Linden Avenue

    Owen sees holds on his own branch's customers only, with the words to explain each one and a button to request an early release with a reason. Reviews by fraud or BSA teams never appear here. His request for Theo Marchetti, $7,475.00, goes to deposit operations, where it is decided from the collected-funds evidence with a maker and a checker.

    Because the checks you deposited Tuesday add up to more than $6,725, we hold the part above that for a few extra days.

Who it’s for

Built for everyone who touches Reg CC exception holds.

The same holds, seen by the people who decide, check, explain, govern and audit them: what their day looked like, and what it looks like now.

JO
Janelle OkoroDeposit operations specialist · decides 12 to 15 exception holds a morning, plus early releases and branch questions
Deposit Operations Specialist
Before
Picks a reason from a list in the teller or core system, counts business days by hand around holidays and cutoffs, and types the notice.
Now
Opens each flagged deposit with the exception proven, every slice dated and the notice drafted, then approves as the maker, changes the exception with a reason code, or releases at normal availability.
CF
Curtis FenwickSecond specialist on every hold, extension and early release
Deposit Operations Checker
Before
Catches a wrong date only by counting the business days again himself.
Now
Checks a five-point list beside the same strip and notice, approves and sends, or returns the decision to the maker with a reason. He never checks a decision he made.
MC
Miriam CastellanoCompliance officer · owns the funds availability policy and the notice templates
Compliance Officer
Before
Finds out whether branches apply the policy the same way from samples, complaints and exam findings.
Now
Reads a quarterly consistency report by branch, channel and neighborhood with the facts behind each flag, approves corrective actions, and approves every settings change.
OL
Owen LairdBranch manager · explains holds at the desk and asks for early releases
Branch Manager, Linden Avenue
Before
Has no words ready when a customer asks why their money is held.
Now
Sees his branch's holds with a plain script for each, prints the customer's notice, and requests an early release with a reason.
GP
Gail PruettInternal auditor · reads everything, changes nothing
Internal Auditor
Before
Rebuilds holds, notices and reasons from several systems before every exam.
Now
Filters one trail of every person and agent step, and builds a masked examiner pack.
Built on the engine

6 agents. Each with one job, and hard limits.

Six agents pick the exception, prove it, count the business days and draft the notice; a specialist approves and a second specialist checks.

Intake agent

Reads each check deposit from item processing, remote deposit capture and the ATM network: the image, the MICR line, the channel and cutoff, and the account facts from the core. Adds up the day's deposits per account and flags those that meet an exception trigger.

  • Never places a hold or contacts a customer
Hold agent

Picks the Regulation CC exception that applies, or none; writes the facts behind it in one sentence with each source; refuses exceptions the rule does not allow, such as a missing-indorsement redeposit or reasonable cause resting on an impression rather than facts.

  • Never decides below its 0.85 floor; a specialist picks instead
Date agent

Works out the banking day of deposit from the channel's cutoff, then each slice's availability date: the next-day amount, the normal schedule and the exception's reasonable period, skipping weekends and Federal Reserve holidays.

  • Never guesses a date; an unknown holiday stops it
Consistency agent

Finds the most recent comparable deposits (same exception, amount band, account type and age) and shows how the bank decided them, by channel and branch; reports quarterly disparities to compliance.

  • Never changes a decision; it shows the pattern and who departed from it
  • Needs at least 200 comparable deposits
  • Never uses names, ages or any protected characteristic
Notice agent

Writes the exception hold notice from the approved template with the account, the deposit, the amount delayed, the reason and the availability date; checks its timing and that nothing in it hints at a fraud review.

  • Never sends a notice before the checker approves
Release agent

Watches presentment, returns and notices of nonpayment; proposes early releases once funds are collected under the bank's rule CF-1, and extensions when new facts arrive.

  • Never releases or extends a hold without a maker and a checker
Deposit Operations Specialist and Checker

Maker and checker on every hold, extension and release; compliance on policy. The agents propose; a named person decides.

Ask in plain words

Ask about any deposit, hold, notice or rule

Ask in plain words, or say what to do. Every answer cites the deposit record, the image or the regulation, then opens the screen it is about.

Why is $3,125 of Marisol Ferrante's deposit held until October 22?

Because $3,125.00 is the part over the $6,725 large-deposit amount. She deposited one $9,850.00 check by mobile at 6:42 PM on Tuesday, before the 8:00 PM cutoff. Under the large-deposit exception the first $6,725.00 keeps its normal availability: $275.00 today and $6,450.00 Thursday. The rest gets a reasonable period of five more business days, so Thursday, October 22. Tessaly placed the same hold on 480 of 500 comparable deposits.

Which of today's proposals did the agents refuse to hold, and why?

Six deposits stay at normal availability because the rule does not allow the hold. Rosalind Vey's check came back only for a missing indorsement. Harold Quist's U.S. Treasury check drew a teller's reasonable-cause request with only an impression behind it, "customer seemed rushed", and reasonable cause needs facts. Corinne Albrecht's account turned 31 days old. Three others were closed earlier: two business accounts with approved arrangements and one account with five overdrawn days, not six.

Draft the extension for Pruitt Lawn & Landscape after the stolen-check notice

Drafted, for your approval and Curtis Fenwick's. Brookhollow Bank told us at 4:12 PM yesterday that the drawer reported check 40118 stolen. That is a fact pointing to nonpayment, so the hold moves to reasonable cause. The new notice must go by today, the first business day after the facts became known. The customer notice says only that we have reason to believe the check may not be paid; the fraud case stays internal.

Are we applying reasonable-cause holds the same way at every branch?

Not at Harlow Street. It takes 4.2% of Tessaly's check deposits but placed 31 of the 214 reasonable-cause holds last quarter, 3.5 times its share. Twenty-two came from teller requests, and nine have no facts statement. Large-deposit holds are even across channels and neighborhoods. Miriam Castellano opened a review yesterday.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

One deposit: the check, a strip of business days, the exception and one decisionA deposit operations specialist opens a flagged mobile deposit. The check image sits on the left with numbered findings; on the right, a business-day strip shows when each slice becomes available: $275.00 next day, $6,450.00 on the normal schedule and $3,125.00 on a large deposit exception hold to October 22, with weekends and Columbus Day hatched out.
The morning brief: what the agents found, and the notice clockThe day starts with a short brief from the agents in plain sentences, each with one button: 14,860 check deposits read, 92 that met an exception, 6 the rule does not allow. Beside it, the clock for the 5:00 PM hold notice deadline and the specialist's own list.
Would we do this for everyone? 500 comparable depositsBefore anyone decides, the consistency agent shows how the bank decided its most recent comparable deposits, by amount and channel: held on 480 of 500, and the 20 released each with a reason code. Names, ages and protected characteristics are never used.
The Reg CC hold notice as it will print, checked against the ruleThe notice is drafted from the approved template with every item the hold notice requirements name, and each field opens its source. A checklist confirms the content, the timing and that nothing hints at a fraud review; a preview shows what the customer sees in online banking.
Approved by the maker, checked by a second specialist, placed and sentThe specialist approves as the maker; a second specialist checks a five-point list and approves. Only then does the hold go to the core and the notice to the customer, and both steps land on the audit trail.
Six deposits the agents refused to hold, each with the ruleThe exception holds list filtered to the deposits where the agents propose no hold, because Regulation CC does not allow one: a redeposit returned only for a missing indorsement, a reasonable-cause request with no facts behind it, an account past its first 30 days, overdrafts that fall short of the test.
A teller asked for a hold on a Treasury check; the agents said no, and whyA teller asks for a reasonable-cause hold on a Treasury check because the customer seemed rushed. That is an impression, not a fact, so the agents propose normal funds availability and explain why; a specialist confirms, and the branch gets a plain note.
A reasonable cause hold, written as facts with their sourcesThe facts behind the hold: the return history on the drawer's account and an altered payee pinned on the check image, each with its source. Fraud case management is told separately and never appears on the customer's notice.
Early release on collected funds, in bulk, with a maker and a checkerThe release agent watches presentment and returns and proposes early releases once funds are collected under the bank's rule: 38 holds, $286,940.00. A specialist releases them as the maker and a checker posts them; the agent explains each deposit it left out.
New facts extend a hold, with a new notice the same dayWhen the paying bank reports a deposited check stolen, the agents propose moving the hold to reasonable cause on more of the deposit, cite the notice, and draft the changed-hold notice; the fraud case stays internal.
The branch view: what to tell each customer, and a way to askA branch manager sees holds on his own branch's customers only, with the words to explain each hold and a button to request an early release; reviews by fraud or BSA teams never appear here.
Consistency and fair treatment, by branch, channel and neighborhoodEach quarter the consistency agent reports whether holds fall evenly. The compliance officer sees where they do not, such as one branch placing 3.5 times its share of reasonable-cause holds, the facts behind it, and proposed actions to approve.
The audit trail, and an examiner pack built in a minuteEvery decision by people and agents is on the trail with its evidence; the examiner pack gathers holds, notices, facts statements, overrides and agent versions, masked and redacted, for the examiner who asks.
Governance

Reg CC exception holds: cited, checked by a second specialist, on the record.

Six roles, separated by dutyA deposit operations specialist decides as the maker; a second specialist checks; the Compliance Officer owns the policy, the templates and every settings change; a branch manager sees his own branch's customers and requests early releases; an administrator proposes settings and works no holds; an internal auditor reads everything and changes nothing.
Maker and checker on every hold and releaseEvery hold, changed exception, no-hold decision against a proposal, extension and early release, single or bulk, needs a specialist and a second specialist. No one checks their own decision. Nothing reaches the core or the customer before both approve.
Every exception, fact and date opens its sourceEach finding on the check, each fact behind a reasonable-cause hold, each slice's date and each field on the notice opens the passage it came from: the deposit record, the image, the return file, the core history, the bank's policy section or Regulation CC.
Below the floor, a person decidesThe hold agent works to a 0.85 confidence floor and the release agent to 0.90; below it, the specialist picks. Any change to the agents' proposal needs a reason code, RC-01 to RC-06, and "Other" needs a written reason. A new agent version runs on the last 1,200 decided holds before the Compliance Officer can approve it.
No fraud wording on a customer's viewFraud case management is told separately, and a wording check keeps fraud, alert and report terms off every notice and every customer view; branch managers never see reviews by fraud or BSA teams. Account numbers are masked to the last four, and hold records and facts statements are kept five years, where Regulation CC requires two.
One trail and an examiner packWho, what, when, why and which evidence, for every person and every agent step with its version. The examiner pack gathers holds, notices with delivery proof, facts statements, overrides with reason codes, agent versions and the signed consistency report, with account numbers masked and fraud referrals left out.
Configuration

Your funds availability policy, applied the same way

Every amount, period, cutoff and floor is a setting with a version. The administrator proposes a change, and the Compliance Officer approves it before the agents use it.

SettingDefaultChoose from
Large-deposit, new-account and repeated-overdraft amount$6,725Regulation CC amount effective July 1, 2025, with the next-day amount at $275; next review July 1, 2030
Reasonable period, local checks5 business daysOn-us checks 1 business day; part of the bank's policy, version 2026.1
New accounts: checks available onBusiness day 7Policy FA-4.3; no next-day amount during the first 30 days
Collected funds for early release (CF-1)2 business days after presentmentEarly releases wait while the fraud alert feed is behind
Mobile deposit cutoff8:00 PM ETBranch teller and courier 4:00 PM, ATM 2:00 PM, night depository taken on the next banking day
Escalation of undecided holds3:00 PMTo the VP of Deposit Operations; checker turnaround 2 hours; notices by 5:00 PM on the first business day after the banking day
Hold agent confidence floor0.85Release agent 0.90; the consistency agent needs at least 200 comparable deposits
Keep hold records and notices5 yearsRegulation CC requires 2; anything referred to fraud or BSA is kept 5 years under the BSA rule
Connections

Works with the systems deposit operations already runs on

Core banking systemholds, release dates and account facts
Item processing and check image archivedeposits, front and back images, and returns
Remote deposit capturemobile deposits and their cutoffs
Interbank exchangepresentment, notices of nonpayment and stolen-check reports
Correspondence and notice systemnotices, mail batches and delivery proof
Fraud case managementalerts in, internal referrals out
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of reasonable-cause holds carry the facts and their source
Facts with a source
every reasonable-cause hold
target
Same day
notice for every hold, with the amount, the reason and both dates
Typed by hand, mailed latenext day or later
With agentssame day
typical
$6,725
large-deposit amount since July 1, 2025, applied to the cent on every deposit
Forms still at $5,525$6,725 everywhere

“demo” = seen in the working solution, on its sample data · “target” = the design goal, to be measured in the live solution · “estimated” = our estimate · “typical” = published figures (Federal Reserve Board and CFPB, “Availability of Funds and Collection of Checks”, Federal Register, May 20, 2024, on federalregister.gov: the $6,725 amount, up from $5,525, effective July 1, 2025; 12 CFR 229.21(a) on ecfr.gov: additional damages of $100 to $1,000 in an individual action). Rules named: Regulation CC, 12 CFR 229.10(c), 229.13(b), (e), (g) and (h), and 229.21(a). Tessaly Community Bank, Kestrel Ridge Bank, Merriwell Savings Bank, Brookhollow Bank, Halvorsen Motor Group LLC and the people, businesses, checks, accounts and numbers named on this page are fictional: characters and sample data in the working solution.

Questions

What deposit operations teams ask about Reg CC exception holds.

What is Reg CC Exception Holds?

Reg CC Exception Holds is software for deposit operations teams that decide Regulation CC exception holds on check deposits. Six agents read each flagged deposit, pick the exception that applies or refuse one the rule does not allow, write the facts with their sources, count the business days past weekends and holidays, compare the decision with the bank's own past holds, and draft the hold notice. A specialist approves as the maker and a second specialist checks before the hold is placed and the notice is sent.

What are the Reg CC exception hold reasons?

Regulation CC names six: new accounts, large deposits (checks totaling more than $6,725 on one banking day, since July 1, 2025), redeposited checks, repeated overdrafts, reasonable cause to doubt collectibility, and emergency conditions. The hold agent picks the one that applies, or none, and says why. In the working solution it refuses a redeposit returned only for a missing indorsement, a reasonable-cause hold on a U.S. Treasury check with only a teller's impression behind it, and a new-account hold on day 31.

How long can a Reg CC exception hold last?

Only for a reasonable period past the normal schedule. Under 12 CFR 229.13(h), an extension of up to one business day for an on-us check and five business days for a local check is reasonable, and the bank sets its own periods in its policy. The date agent counts them past weekends and Federal Reserve holidays: Marisol Ferrante's $3,125.00 deposited the day after Columbus Day is available on Thursday, October 22.

What are the Reg CC hold notice requirements?

The notice states the account number, the date and amount of the deposit, the amount being delayed, the reason and the day the funds will be available. It goes at the time of deposit when the customer is there, and otherwise by the first business day after the banking day of deposit. The notice agent drafts it from the bank's approved template, checks all six items and the timing, and it is sent only after the checker approves.

When can a bank place a reasonable cause hold?

When it has facts that give reasonable cause to believe the check is uncollectible, not a teller's impression. The hold agent writes those facts in one sentence with each source, such as returns on the drawer's account or an altered payee on the image. Without timely notice, 12 CFR 229.13(e) bars the overdraft and returned-item fees the hold causes, so the notice is drafted with the decision.

Does the customer ever see a fraud review?

No. When a reasonable-cause hold rests on fraud signals, fraud case management is told separately and marked internal only. A wording check keeps fraud, alert and report terms off every notice and customer view, and branch managers never see reviews by fraud or BSA teams.

Do people stay in control of each decision?

Yes. The agents never place, extend or release a hold, and never send a notice. A specialist approves every decision as the maker and a second specialist checks it; no one checks their own. Below an agent's confidence floor the specialist decides, and any change to a proposal carries a reason code.

How does Reg CC Exception Holds go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your funds availability policy, cutoffs, notice templates and a sample of past holds, and it goes live once every quality gate has passed. We will walk you through it on your own deposits first.

See it on
your exception holds.

We'll run Reg CC Exception Holds on a sample of your own past flagged deposits and hold notices.