Changes to Regulation CC, which implements the Expedited Funds Availability Act become effective July 1, 2025. 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 $225 and adjusts to $275 [*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 $5,525 and adjust to Aggregate amounts over $6,725

Special rules for cash withdrawals (229.12(d)) at $450 and becomes $550

Civil Liability (229.21(a)) $1,100 and $552,500 increases to $1,350 and $672,950

Membership Notification
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.

Ongoing Changes
As mentioned, now that these monetary thresholds are tied to the CPI, you can expect these thresholds to continue to change every 5 years. So, while the thresholds listed above become effective on July 1, 2025, your credit union should also expect additional changes to become effective on July 1, 2030, July 1, 2035, etc. Any bets on whether we still have checks and checking accounts around by then?