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When I visit credit unions, I am frequently asked to review branch signage and posted disclosures. As you may recall, I previously blogged about the HMDA Notice requirement in May. Another required notice that credit unions seem to have difficulty posting properly is the Regulation CC (Funds Availability) lobby notice.
Section 229.18 of Regulation CC states: “A bank shall post in a conspicuous place in each location where its employees receive deposits to consumer accounts a notice that sets forth the time periods applicable to the availability of funds deposited in a consumer account.”
Additionally, the official commentary to Regulation CC states: “The notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits. For example, the notice might be posted at the point where the line forms for teller service in the lobby.”
Credit unions seem to frequently neglect to post their funds availability policy within their branches and unfortunately, many times when they are posted, they are posted in a location that would not be considered “conspicuous.”
So, if your credit union is posting the funds availability notice on a wall within a hallway leading to the credit union’s restroom…you are probably not meeting the “conspicuous” requirement (although it would seem to be very conspicuous or even odd to place it there…and yes, I have seen it posted there).
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