Reg. CC dollar thresholds increasing as of July 1, 2025

NEWS:  The Federal Reserve and CFPB has announced new, inflation-adjusted Reg. CC dollar thresholds that will take effect July 1, 2025. These amounts are updated every five years, based on changes in the Consumer Price Index.  

• Next-day availability (§229.10(c)(1)(vii)): Reg. CC contains a special $225 rule for check deposits not subject to next-day availability. Under the rule, the depositary bank must make available for withdrawal on the next banking day the lesser of $225 or the aggregate amount deposited to all accounts, including individual and joint accounts, held by the same customer on any one banking day. That amount will increase to $275.
   
• Time period adjustment for withdrawal by cash or similar means (§229.12(d)): Special rules apply to cash withdrawals from check deposits. One part of the rule says that a customer must also be allowed to withdraw $450 of the deposited funds (or the maximum amount that can be withdrawn from an ATM, but not more than $450) no later than 5 p.m. on the day funds become available for check withdrawals. The remainder of deposited funds would be available for cash withdrawal on the following business day. That amount will increase to $550.
   
• Exception hold for new accounts (§229.13(a)(1)(ii)): New accounts are subject to a different availability schedule during the first 30 calendar days after they are opened. Under those rules, the first $5,525 of a day’s aggregate deposits of government checks (including federal, state, and local governments), cashier’s, certified, teller’s, or traveler’s checks must be given next-day availability. The amount in excess of $5,525 must be made available no later than the ninth business day following the day of deposit. That amount will increase to $6,725.
   
• Exception hold for large deposits (§229.13(b)): Under the large deposit exception, a depositary bank may extend hold schedules when local and non-local check deposits exceed $5,525 on any one day. A hold may be applied to the amount in excess of $5,525.  That amount will increase to $6,725.
   
• Repeated overdrafts (§229.13(d)(2)): If a customer’s account has been repeatedly overdrawn during the preceding six months, the financial institution may delay the availability of funds from local and non-local checks. A customer’s account may be considered “repeatedly overdrawn” in two ways.  

• First, the exception may be applied if the account (or accounts) have been overdrawn, or would have been overdrawn had checks or other charges been paid, for six or more banking days during the preceding six months. This is not changing.
   
• Second, the exception may be applied to customers who incur overdrafts on two banking days within the preceding six-month period if the negative balance in the account(s) is equal to or greater than $5,525, or if the account would have been overdrawn by $5,525 or more had checks or other charges been paid. These amounts will increase to $6,725. 

Potential liability increasing, too

• For actions by individuals, the civil liability amounts are currently “not less than $100 nor greater than $1,100,” and those amounts will increase to $125 and $1,350.
   
• For class actions, the civil liability amount is currently “not more than $552,500 or 1 percent of the net worth,” and that dollar figure is increasing to $672,950.  

Action steps

• Update your Reg. CC policy to reflect the new amounts.
   
• Ensure that account opening disclosures reflect the new amounts. A financial institution must provide potential customers with Reg. CC disclosures before an account is opened. See Reg. CC §229.17(a).
   
• Check your account ownership terms and conditions forms and update them if they reference the Reg. CC threshold amounts. (The League’s “Your Account Agreement” form (WCUL #82004) does not.)
   
• Ensure that posted Reg. CC notices reflect the updated amounts as necessary. A Federal Reserve publication explains: “Your institution must post, in each location where employees accept consumer deposits, a notice of your availability policy pertaining to consumer accounts. The notice must specifically state the availability periods for the various types of deposits that may be made to consumer accounts. The notice need not be posted at each teller window, but it 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. The notice is not required at drive-through teller windows or at night depository locations, but it is required at all automated teller machines.” See Reg. CC §229.18(b).
   
• Adjust the thresholds amounts in your core processing system.
   
• Send change-in-terms notices to members no later than 30 days after the change. The League’s ii Release No. 0100 explains that ordinarily, a financial institution must send notification of a change to the financial institution’s availability policy to all account holders 30 days prior to implementation if the change will adversely affect them. However, a change that results in faster availability may be disclosed no later than 30 days after implementation. Because these changes expedite the availability of funds (making more money available to members sooner), the notices can be sent within 30 days after the credit union implements these amendments. See Reg. CC §229.18(e).  

  The last time regulators updated these Reg. CC thresholds (effective in 2020), they explained that change-in-terms notices need to list the actual Reg. CC dollar amounts that are changing. They cannot just generally refer to changes required by recent regulatory amendments.
   

• Address the changes in staff training.