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1 TABLE OF CONTENTS... 1 CHAPTER 1 INTRODUCTION GOALS AND OBJECTIVES REQUIRED REVIEW APPLICABILITY... 4 CHAPTER 2 ACCOUNTABILITY AND MONITORING INTERNAL CONTROLS BOARD/SENIOR MANAGEMENT OVERSIGHT... 6 CHAPTER 3 STAFF AND TRAINING ONGOING TRAINING NEW HIRE TRAINING... 8 CHAPTER 4 REGULATION CC OVERVIEW COVERED ACCOUNTS DEFINITIONS... 9 CHAPTER 5 REQUIRED DISCLOSURES INITIAL DISCLOSURE Timing of Initial Disclosure Content of Disclosure Other Disclosure Requirements SPECIFIC AVAILABILITY POLICY DISCLOSURE Timing of Disclosure Content of Disclosure ADDITIONAL DISCLOSURE REQUIREMENTS Deposit Slips Deposit Locations Automated Teller Machines Upon Request Changes in Policy CHAPTER 6 AVAILABILITY OF FUNDS REQUIREMENTS AVAILABILITY SCHEDULE NEXT DAY AVAILABILITY Cash Deposits Electronic Payments

2 6.2.3 Certain Check Deposits Other Availability Requirements AVAILABILITY EXCEPTIONS PAYMENT OF INTEREST MISCELLANEOUS GUIDANCE CHAPTER 7 COLLECTION OF CHECKS RESPONSIBILITY FOR RETURNED CHECKS NOTICE OF NONPAYMENT EXCEPTIONS CHAPTER 8 SUBSTITUTE CHECKS GENERAL REQUIREMENTS WARRANTIES AND INDEMNITY EXPEDITED RECREDITS CONSUMER EXPEDITED RECREDITS BANKS Timing and Content of Claim Response to Claim CHAPTER 9 APPENDIX MODEL AVAILABILITY POLICY DISCLOSURE Next Day Availability, Case by Case Holds and Exceptions Substitute Check Policy Disclosure MODEL AVAILABILITY POLICY CLAUSES Holds on Other Funds for Check Cashing Holds on Other Funds for Other Accounts Appendix B Availability for Nonlocal Checks Automated Teller Machine Deposits (Extended Hold) Cash Withdrawal Limitation Availability of Funds Deposited at Other Locations MODEL AVAILABILITY NOTICES Exception Hold Notice Reasonable Cause Hold Notice One Time Notice for Large Deposit and Redeposited Check Exception Holds One Time Notice for Repeated Overdraft Exception Hold Case by Case Hold Notice Notice at Locations Where Employees Accept Consumer Deposits Notice at Locations Where Employees Accept Consumer Deposits (Case By Case Holds) Notice at Automated Teller Machines

3 9.3.9 Notice at Automated Teller Machines (Delayed Receipt) Deposit Slip Notice Expedited Recredit Claim, Valid Claim Refund Notice Expedited Recredit Claim, Provisional Refund Notice Expedited Recredit Claim, Denial Notice Expedited Recredit Claim, Reversal Notice

4 Introduction Goals and Objectives Chapter 1 Introduction is committed to the highest standards of federal consumer compliance and requires all management, employees, and third party vendors to follow these policies and adhere to these standards. 1.1 Goals and Objectives The standards set out in this policy represent minimum requirements based on applicable legal and regulatory guidance and apply throughout s operations. These requirements are intended to prevent, its employees, and third party vendors from violating federal regulations related to banking and consumer compliance with respect to availability of funds, collection of checks and other requirements included in the Expedited Funds Availability Act and Regulation CC. 1.2 Required Review requires this policy be reviewed no less than annually. The review shall include the compliance of this policy with current law, regulation or directive, the procedural implementation of this policy within the then current scope of s business lines and operations, internal or external audit results received during the previous year, and then current industry trends or regulatory guidance. 1.3 Applicability The purpose of this policy is to implement consumer protection mechanisms as required by the United States statutes and related federal regulations administered by the Consumer Financial Protection Bureau (CFPB) and other prudential regulators as identified by the CFPB including the Board of Governors of the Federal Reserve System (FRS), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC). Wherever state or local regulations overlap and are stricter than the requirements set out in this policy, the more conservative approach shall be applied. If any applicable laws or prudential regulator requirements conflict with this policy, must consult with the appropriate legal counsel to resolve the conflict and to set forth s policies and procedures for compliance.. 4

5 Regulation CC Overview Covered Accounts Chapter 4 Regulation CC Overview The Expedited Funds Availability Act (EFAA) was enacted in 1987 and was implemented by Regulation CC. Regulation CC governs the availability of funds deposited in checking accounts and the collection and return of checks and requires banks to make funds deposited in transaction accounts available to their customers within specified time frames; pay interest on interest bearing accounts not later than the day the bank receives credit; and disclose funds availability policies to customers. 4.1 Covered Accounts Accounts subject to Regulation CC include accounts at a bank from which the account holder is permitted to make transfers or withdrawals by negotiable or transferable instrument payment order of withdrawal telephone transfer electronic payment; or other similar means for making payments or transfers. Accounts subject to Regulation CC also include accounts at a bank from which the account holder may make payments at an automated teller machine (ATM), remote service unit or another electronic device, including debit card. Savings accounts or money market accounts are generally not subject to Regulation CC. [ Client] may choose to apply funds availability policies to all accounts, even if certain accounts are not subject to Regulation CC requirements. 4.2 Definitions Following are common terms used in this policy: Banking Day A business day on which a bank is open for substantially all its banking activities. Even though a bank may be open for regular business on a Saturday, that day is not a banking day for the purpose of Regulation CC because Saturday is not a business day under the regulation. Business Day. 9

6 Availability of Funds Requirements Availability Schedule Chapter 6 Availability of Funds Requirements Funds are considered received and deposited according to the following: Funds deposited through a staffed facility, ATM or contractual branch of are considered deposited upon receipt. Funds mailed to are considered deposited on the day they are delivered to. Funds deposited to a night depository, lock box or similar facility are considered deposited on the day on which the deposit is removed from such facility and is available for processing by [ Client]. Funds deposited at an ATM that is not on or within 50 feet of the premises of are considered deposited on the day the funds are removed from the ATM and, if the ATM is not serviced at least twice each week, must post a notice at the ATM informing depositors that funds deposited at the ATM may not be considered received on the date of deposit. Funds may be considered deposited on the next business day if the deposit occurred o on a day that is not a banking day for ; or o after a cut off hour set by for the receipt of deposits of 2:00 p.m. or later at its main office or branches or for the receipt of deposits at ATMs, contractual branches or offpremise facilities of 12:00 p.m. or later. Note: Different cut off hours later than these times may be established for the receipt of different types of deposits or for receipt of deposits at different locations. On the applicable day funds are required to be made available, the funds must be available for withdrawal by the later of 9:00 a.m. (local time) or the time s teller facilities, including ATMs, are available for customer account withdrawals. may not place a hold on any funds greater than the amount of the deposit for which the funds availability policy applies. 6.1 Availability Schedule The following deposit types must be made available for withdrawal not later than the second business day following the banking day on which funds are deposited: A local check A check drawn on the Treasury of the United States that is not governed by next day availability requirements. 15