Regulation CC exception holds let a bank delay access to deposited funds beyond the normal availability schedule, but only when one of six specific triggers applies: a new account, a large deposit, a redeposited check, repeated overdrafts, reasonable cause to doubt the check will be paid, or an emergency. Each trigger has its own rules, and each extension has a presumptive maximum. The key dollar figures were reset on July 1, 2025, with the large-deposit threshold at $6,725 and the minimum next-day availability amount at $275; the next scheduled adjustment is July 1, 2030.1eCFR. 12 CFR 229.11 – Adjustment of Dollar Amounts
Exception holds apply to check deposits. Cash and electronic deposits generally keep their next-business-day availability even when other parts of a deposit are held, and the first $275 of a day’s check deposits must still be released by the next business day in most settings.2eCFR. 12 CFR 229.10 – Next-Day Availability
The Six Exception Categories
Under 12 CFR § 229.13, a bank may extend normal hold periods only for one of the following reasons, and only on the portion of the deposit that meets the criteria.3eCFR. 12 CFR 229.13 – Exceptions
New Accounts
An account is “new” during its first 30 calendar days. It is not treated as new if the customer already had another account at the same bank for at least 30 days within the previous 30 days. During the new-account window, cash and electronic deposits still receive next-business-day availability. For next-day check types such as Treasury checks and cashier’s checks, the first $6,725 deposited on any banking day must be available the next business day; the amount above $6,725 can be held until the ninth business day after deposit. Other check types fall outside the standard § 229.12 schedules entirely during this period.
Large Deposits
If total check deposits on a single banking day exceed $6,725, the bank may place an exception hold on the amount above that threshold. The first $6,725 still follows normal availability. On a $10,000 check, that means $6,725 moves on the ordinary schedule and only the remaining $3,275 can be subject to an extended hold.
Redeposited Checks
When a check that was returned unpaid is deposited again, the bank may apply an extended hold. Two situations are carved out. If the check was returned solely for a missing endorsement and the endorsement has since been added, the exception does not apply. The same is true for a post-dated check that has since reached its date. The return-reason notation on the check must match the carve-out for either exclusion to work.
Repeated Overdrafts
This exception becomes available when the account’s balance was negative, or would have been negative if all charges had cleared, on six or more banking days within the previous six months. It also applies if the account was overdrawn by $6,725 or more on at least two banking days during that period.
Reasonable Cause To Doubt Collectibility
A bank can delay availability when it has a well-grounded belief that a specific check will not be paid. The belief must rest on specific facts, not generalizations. A bank cannot invoke this exception because of the type of check or because of the category of person depositing it. The specific facts behind the doubt must be included in the hold notice and retained in the bank’s records.
Emergency Conditions
Natural disasters, widespread communication failures, and similar events that prevent normal check processing allow the bank to suspend standard availability. Funds must be released within a reasonable time after the emergency ends or after the standard hold period would have expired, whichever is later.4eCFR. 12 CFR Part 229 – Availability of Funds and Collection of Checks (Regulation CC)
How Long an Exception Hold Can Last
Regulation CC defines what counts as a reasonable extension, and those periods are added to the standard hold rather than used in place of it.4eCFR. 12 CFR Part 229 – Availability of Funds and Collection of Checks (Regulation CC)
- On-us checks that would otherwise get next-day treatment under § 229.10(c)(1)(vi): up to one additional business day, for a total of two business days from deposit.
- Checks on the two-business-day schedule under § 229.12(b): up to five additional business days, for a total of seven business days from deposit.
- Checks on the five-business-day schedule and deposits at nonproprietary ATMs under § 229.12(c) and (f): up to six additional business days, for a total of eleven business days from deposit.
A bank can hold funds longer than these windows, but doing so shifts the burden onto the bank to prove the longer hold was justified by the specific facts and that it acted in good faith.
What the Exception Hold Notice Must Tell You
When a bank invokes any of the exceptions for large deposits, redeposited checks, repeated overdrafts, or reasonable cause, it must give the customer a written notice that includes five pieces of information:
- An identifier for the account, which can be as short as a four-digit code.
- The date of the deposit.
- The specific dollar amount being held, not the total deposit.
- The reason for the hold, meaning which exception category applies. For reasonable-cause holds, the notice must go further and state the specific facts behind the doubt about collectibility.
- The date the held funds will become available for withdrawal.
If a bank invokes the reasonable-cause exception, it must also keep a written record of each notice and a brief statement of the facts behind it, so regulators can review whether the stated reason was legitimate.5eCFR. 12 CFR 229.13 – Exceptions
Timing of the Notice
When a deposit is handed to a bank employee in person and the hold is applied at that moment, the notice must be given to the customer on the spot. If the hold decision comes later, or if the deposit was made at an ATM or through another channel where in-person notice is not possible, the bank must mail or deliver the notice no later than the first business day after it learns of the facts triggering the hold or after the deposit is made, whichever is later.6eCFR. 12 CFR 229.13 – Exceptions – Section: Notice of Exception
How ATM and Mobile Deposits Change the Math
Where you deposit a check affects which baseline schedule applies before any exception is layered on.
A proprietary ATM, meaning one owned by or located at your bank, is treated the same as a branch. A nonproprietary ATM carries a longer baseline hold of five business days for both cash and check deposits, and a reasonable exception extension there can add six more business days, for a potential eleven in total. The $275 next-day availability safeguard does not apply to nonproprietary ATM deposits.7Federal Reserve. A Guide to Regulation CC Compliance
Mobile deposits count as check deposits under Regulation CC because the regulation treats electronic images of checks as checks for collection purposes. Exception holds can be applied to mobile deposits on the same terms as any other check deposit, though many banks also layer their own mobile deposit policies on top.4eCFR. 12 CFR Part 229 – Availability of Funds and Collection of Checks (Regulation CC)
If the Hold Looks Improper
Under 12 CFR § 229.21, a bank that fails to comply with the availability rules faces civil liability. An individual customer can recover actual damages plus statutory damages of no less than $125 and no more than $1,350.8eCFR. 12 CFR 229.21 – Civil Liability Actual damages matter most when an improper hold caused bounced checks, late fees, or other out-of-pocket losses. For class actions, total recovery cannot exceed the lesser of $672,950 or one percent of the bank’s net worth. These figures took effect July 1, 2025, and are next scheduled for adjustment on July 1, 2030.
Start by asking the bank’s compliance department to name the specific exception it invoked and the facts supporting it. For a reasonable-cause hold, the bank is required to have documented its reasoning, so requesting that documentation is a legitimate first step. If the bank cannot point to a valid exception or its stated reason does not hold up, the Consumer Financial Protection Bureau accepts complaints through its website and routes them to the institution for a response.