Changes to Regulation CC, which implements the Expedited Funds Availability Act become effective July 1. Also known as the “how long can I hold a check before giving the member the funds” regulation, your credit union should be planning to implement the changes and provide timely notice to your membership.
In summary, these changes increased several of the monetary limits within the regulation and tied them to a formula that is derived from data within the Consumer Price Index. While these changes fall short of addressing a much needed overhaul of the regulation generally (non-local checks are still referenced), it did make changes that will require your credit union to take action, potentially make changes to your core system, and communicate with members.
Summary of the Changes
Next day availability (229.10) is currently $200 and adjusts to $225 [*this is the most commonly used threshold that is changing]
Large Deposit (229.13(b)), New Account (229.13(a)) and Repeated Overdraft (229.13(d)) limits
currently aggregate amounts over $5,000 and adjust to Aggregate amounts over $5,525
Special rules for cash withdrawals (229.12(d)) at $400 and becomes $450
Civil Liability (229.21(a)) $1,000 and $500,000 increases to $1,100 and $552,500
Credit unions need to provide the appropriate change-in-terms notice to your checking (transaction) account members. That can be done through a statement message, a newsletter, a letter, or in any manner that informs each impacted account owner of the revised thresholds. (Sorry, just a website notice is still not acceptable.) Since the change is to the advantage of the member, the credit union can disclose the change up to 30 days after implementation. Ensure your account terms booklets, data system, and any training materials are also updated to reflect the new amounts.
As mentioned, now that these monetary thresholds are tied to the CPI, you can expect these thresholds to change every 5 years. So, while the thresholds listed above become effective on July 1, 2020, your credit union should also expect additional changes to become effective on July 1, 2025, July 1, 2030, etc.