If your institution declares an interest-bearing account to be closed causing the consumer to forfeit accrued and uncredited interest, and if the consumer subsequently makes a deposit to that account, new disclosures must be given. In the case of non-interest bearing accounts, if your institution takes action which would officially close a consumer's account when all funds are withdrawn and the consumer would be required to open a new account when a deposit is made, new disclosures would need to be provided. In fact, such a policy would make compliance with Regulation E and Regulation DD easier. Regulation E, the Electronic Fund Transfer Act, requires institutions to mail or deliver periodic statements at least monthly when an electronic fund transfer occurs, and if no electronic fund transfers have occurred for an account which permits electronic access, then a statement must be mailed at least quarterly. Regulation DD also has certain content requirements for periodic statements.
Banks can safely use either type of hold.
The examiners verify the reasons on the exception-based hold notices, and the timing of availability of funds for both types of hold notices, in addition to checking that no one particular type or class of check always has holds placed on it. Either type of hold can be used without criticism of the examiners. However, the hold notice must reflect the availability schedule of the deposit. A bank can place a hold on deposits made to accounts which are repeatedly overdrawn. Or, if endorsements are missing, the bank does not have to accept the check for deposit.