Reg CC Exception Holds: When Each One Applies

10/2/2026

A Reg CC hold is lawful in two ways. Either the bank is holding funds within the ordinary availability schedule, or it has invoked one of the exceptions in 12 CFR 229.13 that lets it go beyond that schedule. The first needs no special justification. The second needs a qualifying trigger, a hold no longer than the rule allows, and in most cases a written notice that says exactly why.

This guide takes the exceptions one at a time: the trigger, the extended hold period, and the notice. It is written for tellers who place holds, new-accounts and deposit operations staff who configure them, and compliance officers who test them. For the availability schedule itself and the next-day categories, start with our Regulation CC funds availability guide.

All dollar figures below are the amounts in effect since July 1, 2025. Regulation CC adjusts them for inflation every five years, and the next scheduled adjustment is July 1, 2030, so any job aid built from this page should carry a review date.

The Baseline the Exceptions Extend

Exceptions only make sense against the schedule they extend. In brief:

• Next-day items (229.10): cash deposited in person to an employee, electronic payments (wire and ACH credits), U.S. Treasury checks deposited into a payee's account, and, under conditions such as in-person deposit and deposit into the payee's account, Postal Service money orders, Federal Reserve Bank and Federal Home Loan Bank checks, state and local government checks, cashier's, certified and teller's checks, and on-us checks.
• The next-day minimum: the lesser of $275 or the day's aggregate deposit of other checks must be available the next business day.
• Other checks (229.12): available by the second business day after the banking day of deposit. Since the Federal Reserve consolidated to a single check processing region in 2010, essentially every check is a local check.
• Nonproprietary ATMs: deposits at an ATM the bank does not own or operate may be held to the fifth business day.

An exception lets the bank hold beyond these periods. If a hold stays within the ordinary schedule, it is not an exception hold and does not need an exception reason, although a bank that normally gives faster availability than the rule requires must still follow its case-by-case notice rules.

What an Exception Can and Cannot Touch

Three limits apply to all exceptions and are worth teaching before any individual exception.

Cash and electronic payments are off limits. Every exception in 229.13 applies to check deposits. The large-deposit exception expressly excludes cash and electronic payments, and the new-account exception keeps cash and electronic payments on next-day availability. A teller cannot put an exception hold on a cash deposit.

The extension must be reasonable. For every exception except new accounts, 229.13(h) allows the bank to extend the ordinary period by a "reasonable period," and defines what is reasonable:

Type of check	Ordinary availability	Reasonable extension	Latest day with the extension
On-us check (same bank, same state or region)	1st business day	Up to 1 business day	2nd business day
Local check	2nd business day	Up to 5 business days	7th business day
Nonlocal check or nonproprietary ATM deposit	5th business day	Up to 6 business days	11th business day

 

A longer extension may be reasonable, but the bank carries the burden of proving it. For next-day items such as cashier's checks or Treasury checks, the extension is added to the schedule that would have applied had the check not qualified for next-day treatment, so a held cashier's check drawn on another bank runs on the local-check timeline plus the extension.

The $275 can fall away. When a bank places or extends a hold under the repeated-overdraft, reasonable-cause, or emergency-conditions exception, the official commentary says it need not make the first $275 available the next day. Under the large-deposit exception, the first $6,725 keeps its ordinary availability, including the $275 next-day minimum.

Exception 1: New Accounts

Trigger. An account is new during the first 30 calendar days after it is established, and the commentary treats it as opened when the first deposit is made. It is not new if each customer on it has had another transaction account at the bank for at least 30 calendar days, either currently or within the 30 days before the new account was opened.

What changes. During the new-account period:

• Cash and electronic payments keep next-day availability.
• Treasury checks, Postal money orders, Federal Reserve and Federal Home Loan Bank checks, state and local government checks, cashier's, certified and teller's checks, and, for this exception only, traveler's checks keep their next-day (or second-day) treatment for the first $6,725 deposited on any banking day. The excess must be available no later than the ninth business day after the banking day of deposit.
• On-us checks, the $275 next-day minimum, and ordinary local checks have no maximum hold period under the regulation.

Notice. The new-account exception is the one exception that does not require a hold notice under 229.13(g). The bank's initial availability disclosure must still describe it if the bank uses it.

New-account holds are a large enough topic that we cover them separately, including who qualifies as an existing customer, but the most common error is simple: the system keeps applying new-account treatment after day 30 because nobody configured it to stop.

Exception 2: Large Deposits

Trigger. The aggregate amount of checks deposited on any one banking day exceeds $6,725. Where a customer has multiple accounts, the bank may aggregate deposits across them, even when the customer is not the sole owner and not all owners are the same. Two individual accounts in the same name, an individual account plus a joint account with a common name, or two joint accounts with at least one name in common may all be combined.

What changes. Only the amount above $6,725 can be held under the exception. The first $6,725 receives whatever availability it would otherwise get. When the deposit mixes check types, the bank chooses which portion to hold. The commentary's own example: a customer deposits $2,000 in cash and a $9,000 local check on Monday. On Tuesday, $2,275 must be available (the cash plus $275 of the check). By Wednesday another $6,450 must be available under the local schedule. Only the remaining $2,275 may be held under the exception, for up to the reasonable period.

Notice. A written notice under 229.13(g)(1) for each hold, or, for a nonconsumer account where the bank will apply the exception to most check deposits to which it could apply, a one-time notice under 229.13(g)(2).

The classic error here is holding the whole check because the amount "looked large." The exception never reaches the first $6,725.

Exception 3: Redeposited Checks

Trigger. A check that was returned unpaid and has been redeposited, whether by the customer or by the bank. The banking day of redeposit counts as the day of deposit.

Carve-outs. The exception does not apply to a check returned for a missing indorsement and redeposited after the indorsement has been obtained, if the return reason on the check says missing indorsement. Nor does it apply to a check returned because it was postdated, if the return reason says so and the check is no longer postdated when redeposited.

Related point. If the bank made $275 of the original deposit available and the check came back, it can charge back the full amount and need not make that $275 available again on redeposit.

Notice. Per-deposit notice, or the one-time notice for nonconsumer accounts on the same conditions as large deposits.

Exception 4: Repeated Overdrafts

Trigger. The bank may treat a customer's account as repeatedly overdrawn if either test is met:

1. On six or more banking days within the preceding six months, the account balance was negative or would have been negative if checks or other charges had been paid; or
2. On two or more banking days within the preceding six months, the balance was negative, or would have been, by $6,725 or more.

The commentary explains that the first test can be met by separate incidents or by a single negative balance that lasts six banking days, and that a dishonored item counts as an overdraft only on that day. Overdrafts caused by ACH debits, point-of-sale transactions and fees count, not only checks. Overdrafts caused by the bank's own error, or by fees the customer is entitled to have refunded because of a hold, do not count. Accounts with overdraft lines of credit are excluded unless the line was exceeded.

What changes. The exception applies to any of the customer's accounts for six months after the last overdraft.

Notice. Per-deposit notice, or a single notice under 229.13(g)(3) for each period during which the exception will be in effect, if the bank will invoke it for most check deposits. That notice must state the account number, that availability is delayed because the repeated-overdraft exception is being invoked, when deposits will generally be available, and the period during which the exception applies.

The test is mechanical, which is its strength. "This customer bounces checks" is not enough; the account history either meets one of the two tests or it does not.

Exception 5: Reasonable Cause to Doubt Collectibility

Trigger. The bank has reasonable cause to believe the check is uncollectible from the paying bank. The regulation defines that as facts that would cause a well-grounded belief in the mind of a reasonable person, and it prohibits basing the belief on the fact that the check is of a particular class or is deposited by a particular class of persons.

Examples the commentary accepts:

• A notice from the paying bank that the check is being returned unpaid.
• Information from the paying bank before presentment that payment has been stopped or that the drawer's account lacks sufficient funds.
• A stale-dated check, deposited more than six months after its date.
• A postdated check.
• Confidential information, such as a reasonable belief that the depositor is kiting, or that the drawer or the paying bank is insolvent.

Examples the commentary rejects: holding a check because it is drawn on a rural bank and the bank will not learn of nonpayment in time, or because of the depositor's race or national origin. The same logic rules out "new customer," "large item," or "out-of-state check" as reasons in themselves.

Notice. The 229.13(g)(1) notice must include the reason the bank believes the check is uncollectible. Model notice C-13 in Appendix C lists sample reasons, but the commentary says the list is not exhaustive.

Recordkeeping. This is the only exception with its own record requirement. Under 229.13(g)(5), the bank must keep a record of each reasonable-cause notice together with a brief statement of the facts that gave rise to the doubt, retained for at least two years under 229.21(g).

Fees. If the bank does not give written notice at the time of deposit, it may not charge overdraft or returned-check fees caused by the hold if the check is ultimately paid, unless its notice told the customer that such fees may be refunded and how to request a refund, and it refunds them on request.

The reasonable-cause exception is where most of the judgment and most of the risk sit. Check fraud schemes often surface here first; our post on check fraud detection covers the red flags that can supply a documented, item-specific reason.

Exception 6: Emergency Conditions

Trigger. An interruption of communications, computer or other equipment; a suspension of payments by another bank; a war; or an emergency condition beyond the bank's control, provided the bank exercises the diligence the circumstances require. The commentary gives severe weather delaying a check in collection as an example.

What changes. The bank may extend the hold until a reasonable period after the emergency ends, or the ordinary schedule, whichever is later.

Notice. Notice in a reasonable form and within a reasonable time. Where the emergency affects the paying bank, the commentary suggests the usual exception-notice timing is likely reasonable. Where the depositary bank's own operations are down, a general notice through branch and ATM postings or public media may be reasonable. No notice is needed if the funds become available before the notice would have to be sent.

Emergency conditions do not cover cash or electronic payments. A delay in making those available because of a genuine computer malfunction is analyzed instead under the bona fide error defense in the civil liability section.

The Exception Notice: Content and Timing

For the large-deposit, redeposited-check, repeated-overdraft and reasonable-cause exceptions, the standard notice under 229.13(g)(1) must include:

• A number or code, not more than four digits, identifying the account
• The date of the deposit
• The amount of the deposit being delayed
• The reason the exception was invoked
• When the funds will be available for withdrawal

Timing. For a deposit made in person to an employee, the notice goes to the person making the deposit at the time of deposit. For other deposits, or when the facts supporting the exception become known later, the bank must mail or deliver the notice as soon as practicable and no later than the first business day after the day of deposit or the day the facts become known, whichever is later.

Electronic delivery. The commentary allows electronic notice to a nonconsumer customer who agrees to it, and to a consumer when the bank complies with the E-Sign Act, including the consumer's affirmative consent.

Multiple checks. The notice need not break down each check; it may state the total available at each point in time or explain how the customer can work it out.

Extending a hold again. If new facts justify holding beyond the date in the first notice, the bank must send a second notice with the new availability date.

Model notices C-12 (exception hold), C-13 (reasonable cause), C-14 (one-time notice for large deposit and redeposited check) and C-15 (one-time notice for repeated overdrafts) are in Appendix C and are a safer starting point than a home-grown form. Staff who issue these notices should know the content and timing rules cold, and our Expedited Funds Availability (Reg CC) course is dedicated to this regulation.

Exception Holds at a Glance

Exception	Trigger	Maximum extra hold	Notice
New account	First 30 calendar days, no qualifying existing relationship	Excess over $6,725 of next-day check types to 9th business day; other checks unlimited	Not required per hold; disclose in policy
Large deposit	Checks over $6,725 in one banking day	Excess only, by the reasonable period	Per hold; one-time for nonconsumer
Redeposited check	Returned unpaid and redeposited	Reasonable period	Per hold; one-time for nonconsumer
Repeated overdrafts	6+ negative days, or 2+ days negative by $6,725+, in 6 months	Reasonable period, for 6 months after last overdraft	Per hold or one notice per period
Reasonable cause	Specific facts showing the item may not be paid	Reasonable period	Per hold, stating the reason; record kept
Emergency conditions	Outage, bank suspension, war, emergency beyond control	Reasonable period after emergency ends	Reasonable form and time

 

Where Exception Holds Go Wrong

Annual self-testing tends to find the same five problems:

3. No notice, or a late notice. The single most common Reg CC violation. Sample exception holds and confirm a notice exists, went out on time, and named a permitted reason.
4. Holding the whole large deposit. Only the excess over $6,725 qualifies.
5. Generic reasonable-cause reasons. "Large check" or "new customer" is a class-based reason, not a fact about the item.
6. Repeated-overdraft holds without the test. Pull the overdraft history and confirm one of the two tests was actually met within six months.
7. Stale parameters. Core systems that still carry $5,525 instead of $6,725, or a new-account flag that never expires.

Holds are also part of the bank's fraud defense, and the line between a good fraud control and a Reg CC violation is the documentation. The bank fraud prevention guide shows how holds fit with the other controls.

Frequently Asked Questions

What is a Reg CC hold?

A Reg CC hold is a delay in making deposited funds available for withdrawal, governed by Regulation CC, 12 CFR Part 229. A bank may hold check deposits up to the ordinary availability schedule without special justification, as long as its disclosure describes the policy. To hold longer, it must invoke one of six exceptions in section 229.13: new accounts, large deposits, redeposited checks, repeated overdrafts, reasonable cause to doubt collectibility, or emergency conditions. Most exception holds require a written notice stating the reason and when funds will be available.

What is the Reg CC large deposit hold amount?

Since July 1, 2025, the large-deposit exception applies to the amount of check deposits exceeding $6,725 on any one banking day. Only the excess may be held under the exception; the first $6,725 receives its ordinary availability, including the $275 next-day minimum. Banks may aggregate deposits across a customer's accounts, including joint accounts with a common name. Cash and electronic payments do not count toward the exception. The threshold is inflation-adjusted every five years, with the next adjustment scheduled for July 1, 2030.

How long can a bank hold a check under a Reg CC exception?

For every exception except new accounts, the bank may extend the ordinary schedule by a reasonable period: up to one business day for on-us checks, five business days for local checks, and six business days for nonlocal checks and nonproprietary ATM deposits. A local check held under an exception is therefore usually available by the seventh business day. A longer hold is possible only if the bank can show it is reasonable. For new accounts, special rules apply, including a ninth-business-day limit for the excess of certain checks.

Does a Reg CC exception hold require written notice?

Yes, for the large-deposit, redeposited-check, repeated-overdraft and reasonable-cause exceptions. The notice must identify the account, the deposit date, the amount delayed, the reason, and when funds will be available. It is given at the time of an in-person deposit, or otherwise mailed or delivered no later than the first business day after the deposit or after the facts become known. Emergency holds need notice in a reasonable form and time. New-account holds do not require a per-hold notice.

Can a bank place an exception hold on a cashier's check?

Yes. The large-deposit, redeposited-check, repeated-overdraft and reasonable-cause exceptions can apply to checks that would otherwise receive next-day availability, including cashier's, certified, teller's and government checks. The extended hold is added to the schedule that would have applied had the check not qualified for next-day availability. For new accounts, the first $6,725 of these checks on a banking day keeps next-day treatment and the excess must be available by the ninth business day.

What counts as reasonable cause to doubt collectibility?

Facts that would cause a well-grounded belief in the mind of a reasonable person that the check will not be paid. The commentary's examples include a notice of nonpayment, information that payment was stopped or the drawer lacks funds, a stale-dated or postdated check, and confidential information such as suspected kiting or insolvency. The belief may not rest on the class of check or the class of depositor. The notice must state the reason, and the bank must keep a record of the supporting facts.

Train the People Who Place the Holds

Exception holds are decided in seconds at the counter, and every one of them leaves a paper trail an examiner can sample. Our Expedited Funds Availability (Reg CC) course is dedicated to this regulation and is the natural place to start for tellers, new-accounts staff and deposit operations. For the broader front-line curriculum, see teller training.