New account exception hold v. large deposit exception hold

With NAFCU’s Regulatory Compliance School beginning in less than a month, we thought it would be a good time to revisit a topic that is covered during school: the difference between the new accounts exception hold in section 229.13(a) of Regulation CC and the large deposits exception hold in section 299.13(b). The similar thresholds in both seem to cause some confusion from time to time.

The chart below summarizes how the exception holds work, including their similarities and their differences:


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