WASHINGTON (3/15/10)--The Credit Union National Association (CUNA) has advised credit unions that they may provide a change notice in their newsletter if their current disclosures under Regulation CC are no longer accurate due to the recent elimination of nonlocal checks. However, CUNA, in this month’s Compliance Challenge, warns that that very newsletter may be released after the Reg CC compliance date of March 29. In that case, credit unions must determine the cost benefit of producing a separate mailing. Another option is to simply wait until after the compliance date to inform members. No matter what action a credit union takes, its employees should ensure that their new account disclosures are updated, post information about the changes in their funds availability policies online. In general, credit unions should make as many online notifications as possible, and make sure that information posted in their lobbies and ATMs is correct. Addressing the new check policy more directly, CUNA said that the “reasonable” timeframe for holding a check under one of the Regulation CC exceptions is one extra business day for cashier’s, teller’s, certified, and “on us” checks otherwise subject to next day availability, five extra business days for checks subject to second business day availability, and six extra business days for checks deposited in nonproprietary ATMs. Additional days can be applied to large deposits, re-deposited checks, repeated overdrafts, and other emergency conditions, but the credit union itself is responsible for determining whether or not a given situation requires a longer hold period. For CUNA’s Compliance Challenge, use the resource link.