Expedited Funds Availability Act Policy

Purpose

The Expedited Funds Availability Act was enacted in 1988 to address consumer concerns about the availability of deposits made to member accounts. The Act ensures that deposited funds are available to the member within a reasonable time. The Act is administered by the Federal Reserve Board through Regulation CC.

Policy Statement

It is the policy of Princeton University Federal Credit Union to comply with the requirements of Regulation CC. All required disclosures will be clear and readily understandable, in writing, and in the form the member may keep.

Determining the Availability of a Deposit

The length of the delay is counted in business days from the day of the deposit. Each day is a business day except Saturdays, Sundays and federal holidays. If a deposit is made before 3:00 p.m. on a business day that the Credit Union is open for business, we will consider that to be the day of the deposit. However, if the deposit is made after 3:00 p.m. or on a day we are not open, we will consider that the deposit was made on the next business day we are open.

The length of delay varies depending on the type of deposit and is explained below. NOTE: During any holiday period, funds may not be withdrawn, nor will the Credit Union use the funds to honor checks that may be presented against the account for payment.

Next Day Availability

Funds from the following deposits may be immediately available or available on the first business day after the day of the deposit:

• United States Treasury checks that are payable to you
• Electronic Payments – includes wire transfers & ACH credits, such as social security benefits and payroll payments
• Cash
• State and local government checks that are payable to you
• Cashier’s, certified and teller’s checks that are payable to you (PUFCU issued money orders are considered teller’s checks)
• Federal Reserve Bank checks, Federal Home Loan Bank checks and U.S. Postal Service money orders that are payable to you
• Checks drawn on the Philadelphia Federal Reserve District – hereinafter called “Local Checks”
• “On Us” checks
• The first $100 of all other checks deposited

A deposit mailed to the credit union is considered made when it is received by the Credit Union.

Other Check Deposits – “Non-Local” Checks

The first $100.00 from a deposit of non-local checks will be available on the first business day after the day of the deposit. The remaining funds will be available on the third business day after the day of the deposit. For example, if a deposit of a $700.00 non-local check takes place on Monday, $100.00 of that deposit is available on Tuesday, with the remaining $600.00 available on Thursday.

Determining if a Check is “Local” or “Non-Local”

If the first four digits of the routing number are local numbers, then the check is a local check. Otherwise, the check is a non-local check.

1. Local checks will be available on the first business day after the deposit.
2. Non-local checks – the first $100.00 from a deposit will be available on the first business day after the day of the deposit. The remaining funds will be available on the third business day after the day of the deposit.

Exception Holds

In some instances, the Credit Union will not make all of the funds deposited by check available at the times shown. Depending on the type of check that is deposited, funds may not be available until the seventh business day after the deposit. However, the first $100 of the deposit will be available on the first business day after the deposit.
If the Credit Union is not going to make all funds from the deposit available at the times shown, we will notify the member at the time of the deposit. We will also tell the member
when the funds will be available. If we decide to take this action after the member has left the Credit Union office, we will mail a notice to the member by the first business day after we receive the deposit.

Funds deposited by check may be delayed for a longer time under the following circumstances:

• Checks the Credit Union has reason to believe are uncollectible: We believe a check deposited will NOT be paid, such as when the check is stale dated, the check is payable to 2 parties and the same person appears to have endorsed both names, or the credit union has received notice of dishonor from the paying financial institution.
  
• Large Deposits: Checks totaling more than $5,000 are deposited on any business day. The first $5,000 of such a check is subject to the permanent availability schedule (i.e. for local checks it will be available within one (1) day, for non-local checks it will be available within three (3) days after the deposit).
  
• Redeposited Items: A check that has been returned “unpaid” is re-deposited
  
• Repeat Overdrafts: The account has been overdrawn repeatedly in the last 6 months. Specifically, a member must have been overdrawn six or more separate or consecutive business days within the preceding six months or have been overdrawn by at least $5,000 on two or more business days in the last six months. This exception may not be applied to any deposit subject to next day availability except for cash deposits and electronic payments.
  
• Emergency Conditions: There is an emergency, such as failure of communications or computer equipment.

Exception Hold Notice

We will notify the member if we delay the ability to withdraw funds for any of these reasons and we will tell the member when the funds will be available. The funds will generally be available no later than the seventh business day after the day of the deposit.

The notice will provide the following information: Member’s account number, the day the funds were deposited, the reason the Credit Union has evoked the exception hold, and the day the funds will be available for withdrawal.

Special Rules for New Accounts

An account is defined as a “new Account” during the first 30 calendar days after it has been opened with an initial deposit. If a member has an existing account with the credit union, an additional account opened by the member would not be subject to the exception.

The following special rules apply during the first 30 days the account is open:

The first $5,000.00 from a deposit of U.S. Treasury checks may be immediately available or available on the first business day after the day of the deposit. The excess over $5,000.00 of a day’s total deposits may be available on the fifth business day after the day of the deposit. Funds from wire transfers into the account may be immediately available or available on the first business day after the day we receive the transfer.

Funds from deposits of cash and the first $5,000.00 of a days total deposits of cashier’s, certified, tellers and state and local government checks may be immediately available or available on the first business day after the day of deposit if the deposit meets certain conditions. For example, the checks MUST be made payable to the member. The excess over $5,000.00 may be available on the fifth business day after the day of the deposit.

Funds from all other check deposits will be available on the seventh business day after the day of the deposit.

Disclosure Requirements: Regulation CC requires that the Credit Union provide the following disclosures:

• Initial Disclosure – A disclosure stating the Credit Unions availability of funds policy must be provided before a member opens an account. It must be clear, conspicuous, in writing and in a form the member can keep.
  
• Branch Disclosure – The Credit Union must post a copy of their funds availability schedule at each branch location where funds are deposited. The notice must be in a conspicuous location in the branch lobby and at each ATM location.
  
• Upon Request – Credit Union Employees must provide a copy of the funds availability policy upon request by a member.

Record Retention: Records pertaining to compliance with Regulation CC must be maintained for at least two years.

Regulation CC Expedited Funds Availability
Description	When Funds Are Available
“Immediate Availability” (no hold) (All checks MUST be payable to member) U.S. Treasury Checks, Wire Transfers, Cash, State and Local Government checks, Cashier’s, certified and tellers’ checks, Federal Reserve Bank checks, Federal Home Loan Bank checks and U.S. Postal Money Orders	Immediately
“Local Checks” (1 day hold) 0210, 0212, 0213, 0214, 0215, 0126, 0219, 0220, 0223, 0260, 0280, 0310, 0311, 0312, 0313, 0319, 0360, 2210, 2212, 2213, 2214, 2215, 2216, 2219, 2220, 2223, 2260, 2280, 2310, 2311, 2312, 2313, 2319 and 2360	Available the first business day AFTER the deposit
“Non-Local” Checks (3 day hold) All other Routing Numbers	$100 available AFTER the first business day of the deposit Remaining funds on the third business day after the day of the deposit
New Accounts (All checks MUST be payable to member) U.S. Treasury Checks, Wire Transfers, Cash, State and Local Government checks, Cashier’s, certified and tellers’ checks, Federal Reserve Bank checks, Federal Home Loan Bank checks and U.S. Postal Money Orders	First $5,000 available immediately Remaining funds on the fifth business day after the day of the deposit
New Accounts All “Other” Checks	$100 available AFTER the first business day of the deposit Funds available on the seventh business day after the day of the deposit