Understanding Reg CC

June 2002

A White Paper by Cathy C. Glassman – Principal

w w w. c a r r e k e r. c o m | © Carreker Corporation 2002
 UNDERSTANDING REG CC

INTRODUCTION
Float managers traditionally have been charged with the design and implementation of the
bank's check clearing program including the selection of clearing agents, transportation, and
the design of the sort patterns. But even more significantly, the float manager is responsible
for the availability schedules for customer float assignment. These schedules are used to
determine the availability of funds for investment, withdrawal, payment of checks, and the
calculation of collected balances and corporate earnings credits.

While some banks may have only one availability schedule for all customers, most large
banks have multiple availability schedules designed to match the float sensitivity of a specific
segment of customers. The accurate and appropriate design of these schedules ensures
that the designated segment will meet its float allocation targets and recognize projected
revenue, while other segments may be passed float equal to or less than the bank's own
collection experience. It is during the implementation of these schedules that float managers
must ensure that their designs do not exceed the parameters established by government
laws and regulations covering availability. In our experience as consultants to major banks
across the country, we have encountered a good deal of confusion about the provisions of
these regulations, and how the implementation of float availability schedules is constricted by
these regulations.

PURPOSE
The purpose of this paper is to describe major sections of Regulation CC Availability of Funds
and Collections of Checks (12CFR 229) originally issued by the Federal Reserve Board in
September 1988. This overview is based on reading the regulation and the accompanying
commentary, interviews with Federal Reserve officials and private attorneys, and the
experience of banks across the country in implementing the regulation. This overview is not
a legal opinion, and questions involving specific instances with specific client issues should
be addressed through your compliance officer or legal counsel.

Specifically, it addresses five main areas where confusion often arises, and where banks may
fail to optimize their Reg CC availability schedules:

1. Separating Corporate and Retail Customers

2. Limiting the definition of "Local Items"
3. Paying Interest on Collected Funds
4. Using the right Schedule to Calculate when Interest payments begin
5. Charging Float on Cash and On-Us Items

BACKGROUND
Regulation CC was written in order to implement the Expedited Funds Availability Act (EFAA),
which was passed by Congress in August 1987. The purpose of the act was to set limits on
deposit holds. Until that time, banks, thrifts, and credit unions could set their own funds
availability policies, and there was considerable evidence of abuse, with some banks holding
even local checks for more than 10 days. In response, some states passed individual laws
limiting holds. Portions of these state laws may preempt Reg CC, and are found in Appendix
F of the Regulation.

Understanding Reg CC | www.carreker.com | © Carreker Corporation 2002 2

The Federal Reserve was charged with writing a regulation that would implement the goals
of EFAA. During the course of the public comment period on the proposed regulation it
became clear that the snag in implementing the hold schedule was the way in which return
items were processed, and that major changes to the return system would have to be made.
Until that time, the returning checks followed their forward presentment route, sometimes
through more than one correspondent or Fed office. The return regulations were rewritten,
allowing checks to be returned directly to the Bank of First Deposit (BOFD), or to third parties
for processing and establishing standards for the placement of endorsements and the
readability of endorsements.

The original regulation had a slower or longer availability schedule, called the temporary
schedule, which was introduced to give banks a chance to work out kinks in the return
system. The permanent availability schedule (the current one) went into effect on September
1, 1990.

SCOPE
This paper will not address the return item schedule mentioned above; instead it will
concentrate on the design and application of availability schedules, and how Reg CC impacts
those schedules. This paper will also address strategies and options for float managers to
design availability schedules that are in Reg CC compliance, but also meet the bank's
marketing goals and revenue projections. The section citations like this (12 CFR §229.2(a))
refer to a specific section of the regulation or its official commentary, and may help float
managers clarify portions of the law outlined in this paper. Again, any final changes to the
bank's funds availability policy should be reviewed with the bank's attorneys and/or
compliance department.

THE REG CC OVERVIEW

Reg CC applies to all transaction accounts, both corporate and retail (12 CFR §229.2(a)).
Transaction accounts include checking accounts and checking accounts with interest (NOW
accounts). In addition to the return item provisions outlined above, the regulation states the
longest period of time that funds can be held before making them available for withdrawal
either in cash or through the payment of checks presented against the account.

The maximum availability schedule for checks is often expressed as 1-2-5, that is, one-day
availability for cash, on-us checks, cashiers checks, and government funds; two-day
availability for local items as defined in the regulation, and five-day availability for non-local
items (§229.10). This schedule is the maximum hold allowed for all transaction account
deposits; your bank may allow withdrawals and payments of checks to take place earlier.

Deposits covered in Reg CC generally must be made to a bank employee. Deposits made
at an ATM, and those made into a night deposit box, or other "unmanned" facility, may
receive a longer hold. Electronic payments must be made available not later than the day
after the funds are received. "Received" means that the bank receives final credit and the
payment instructions indicating the customer account to be credited. For wire transfers, final
funds are received when the payment is made, but for ACH payments, final payment is
received on settlement day, but the specific payment instructions may not arrive until after
settlement day. In this case, availability would be delayed until the accounts are credited.

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For items held for more than one day, the first $100 of the total of the deposits for the day at
all branches of the same bank must be made available for cash withdrawal the next day. The
balance of the funds must be made available for cash withdrawal by 5 p.m. on the day
specified in the schedule. At that time, $400 of the deposit must be made available, with the
balance, if any, available the following morning. This provision was designed to limit bank
risk (§229.12(d)). Since the focus in this paper is the design of the availability schedules for
the calculation of the collected balances and earnings credits, this paper will assume that all
funds are made available in full on the day provided in the schedule. In addition to the
additional hold for cash withdrawals, exception holds can be placed for items over $5,000 or
items of questionable collection ranging from two to nine days.

See Permanent Availability Schedule in Attachments A1, A2, and A3.

PAYABLE THROUGH DRAFT AVAILABILITY

When Reg CC was first drafted, it outlined the determination of local and non-local items
based on the routing and transit number (RT) of the check. The credit unions sued the Fed,
claiming that using the RT alone would discriminate against their customers1. Here was their
argument: many credit unions use corporate CU's or third party processors for their share
drafts (checks). The RT number of these payable through drafts is that of the processor. If
a credit union customer's share draft is considered as non-local to other banks, then
merchants and others would be reluctant to accept share drafts as payment, which would
impact the customers and the credit unions. The court held with the credit unions.

According to Reg CC, the fraction in the upper right quadrant of the check is the local/non-
local determinant (§229.2(r)). In most cases, the fraction and the MICR RT number are the
same, and so no accommodation is needed. However, in cases where the issuing bank uses
a payor bank, the fraction would be different from the MICR line. Obviously, this means that
the highspeed check processing sort pattern is unable to determine a local from a non-local
check. Some banks avoid the issue altogether, by setting all consumer availability at no more
than two days for both local and non-local items, to cover the possibility that any payable
through drafts would be deposited.

Some banks have chosen to allow customers to use special deposit slips that would grant
next day availability to payable through items, similar to the deposit slips that are used to
identify Treasury checks. This would allow payable through items to receive local availability,
and still allow the bank to use high speed processing to assign float. The use of special
deposit slips for this specific situation is discussed and the requirements for special deposit
slips are discussed in the commentary to §229.10.

SPECIAL RULES FOR ATM DEPOSITS

ATM deposits have different availability because they are not made at a staffed facility. Reg
CC also differentiates between proprietary ATMs (those owned by the bank) and non-
proprietary ones (those owned by other banks or entities). For proprietary ATMs, cash and
check deposits are available within 2 days, including on-us items (§229.10). Deposits of any
type (cash, local checks, non-local checks) at a non-proprietary ATM are treated like non-
local items and are subject to the 5 day hold (§229.2(aa)). In addition, the first $100

1
Credit Union Nat'l. Assn. Inc. v. Board of Governors, 700 F. Supp. 1152 (DDC 1988).

Understanding Reg CC | www.carreker.com | © Carreker Corporation 2002 4

withdrawal provision does not apply to non-proprietary ATM deposits (§229.12(f)). Just to
make things more complicated, if the ATM machine is more than 50 feet away from the bank
branch, then it is considered non-proprietary, unless it is clearly marked that it is owned by
the bank.

It is important for float managers to walk through the ATM deposit process at the bank to
make sure that the availability granted for the deposit matches the process. For example,
some ATM deposits are not processed until the next business day. In this case, it might be
appropriate to deem all ATM deposits as available next day, which would, in effect, be a two-
day hold.

FLOAT OPPORTUNITIES IN REG CC

While it seems that Regulation CC complicates the process of check collection and the
development of availability schedules, it is possible to work within the regulation to maximize
float options. It's important to remember that the regulation spells out the maximum hold
policy and the minimum RT numbers which must be included. When banks increase the RTs
and decrease the hold policy, they limit their float options. Here are a few ways to make the
most of the regulation's provisions:
1. Establish Classes of Customers
Reg CC sets out the maximum holds allowed on deposits. Availability can be granted
in a shorter time (§229.19(c)). It is also permitted to calculate availability differently for
different classes of customers, including fractional availability. However, the overall
effect of these methods must be that the customer's availability would be no worse than
if the standard schedule (1-2-5) were used.

Fractional Availability is allowed for non-consumer accounts (§229.19(d)) and may be

determined by the use of a sampling. This section establishes the basis for multiple
availability schedules based on market segmentation and float allocation targets.
Some customers may be assigned availability of 2 days on local items, while others
may receive 1.2 or 1.5 days, depending upon their market segment and product
design. Again, the total effect of fractional availability can be no worse than the
standard 1-2-5 hold schedule.

2. Limit the Definition of "Local" Items

One major area where banks lose float opportunity is that the bank's definition of its
"local" items is much broader than the regulation requires. While local items must be
made available no later than 2 business days, many banks offer "local city" items in 1
business day. By expanding the local definition in the customer disclosure greater than
the area required by law, the float manager limits the float options in those areas. The
RT numbers which must be included in the local definition are listed in the Reg in
Appendix A, and in this document in Attachment B.

But remember – in addition to government checks, items drawn on the Federal Reserve
and the Federal Home Loan Bank must be made available next day, and these RTs are
also listed in the Reg in Appendix A, and in this document in Attachment C.

3. Use Collected Balances to Accrue Interest on Savings Accounts

Reg CC requires banks to begin paying interest on interest-bearing accounts "not later
than the day on which the depositary bank receives credit for the funds deposited"

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 (§229.14(a)). While savings and time deposits are not really addressed in Reg CC,
Truth in Savings (Reg DD) (12 CFR 230) does mention when interest must begin
accruing to all interest bearing accounts. This directive clearly indicates that the day
when interest must begin accruing for time deposits is the same as for all other interest
bearing accounts covered under Reg CC (NOW accounts).2 The effect then, is that all
interest bearing accounts are covered by Reg CC, and that interest can be paid on
collected balances.

4. Use the Right Schedule for Interest Bearing Accounts

The regulation also allows banks to rely on their local Federal Reserve or
correspondent mixed cash letter schedule to determine the number of days to use in
the calculation of when funds are collected in interest bearing accounts. Consider
using the local Mixed Other Fed Availability schedule to determine the funds collection
time, selecting the latest deadline available. This schedule includes one, two, and three
day endpoints.

Another alternative to calculate the availability schedule to use for collected savings
balances is the bank's overall collection rate (% of on-us, one-day, and two-day). These
percentages would then be applied to determine what day interest would begin to
accrue for all accounts, regardless of the specific check deposited into any one
account. This alternative is useful if there are systems limitations for the accurate
capture of deposit item information.

5. Charge One Day Availability on Cash and On-Us Items

The regulation allows for next day (the day after the business day of deposit) availability
on cash (§229.10(a)) and on-us items (§229.10(c)(4)). On-us checks receive next day
availability if they are drawn on and deposited into branches of the same bank if both
branches are in the same state OR the same check processing region. So, for
example, if Customer A makes a deposit at the bank's branch in Pittsburgh with a check
drawn on Customer B's account at the Philadelphia branch of the bank, the check is
considered "on-us" and is subject to next day availability. Though they are in different
check processing regions (3rd district – Philadelphia and 4th district – Pittsburgh), they
are in the same state.

"On-we" deposits is a term frequently used to refer to checks drawn on a bank in one
state and deposited in another account of the same bank, but in a different state. These
checks can be considered non-local as long as they are both in different check
processing regions and different states. For example, a check drawn on the Indiana
bank of a multi-state bank is non-local if it is deposited into an Ohio account of the
same multi-state bank.

There is some apprehension by banks when they first discuss charging a day's float for
on-us items. One way to approach the issue is to walk through the bank's actual
deposit process to determine the customer impact. For example, if the tellers are not

2
12 CFR Ch. II (1-1-01 Edition) § 230.7(c) Date interest begins to accrue. Interest shall begin to accrue not
later than the business day specified for interest-bearing accounts in section 606 of the Expedited Funds
Availability Act (12 U.S.C. 4005 et seq.) and implementing Regulation CC (12 CFR part 229). Interest shall
accrue until the day funds are withdrawn.

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 online, then the customer wouldn't be able to take advantage of same day withdrawal
anyway. In addition, there is a fraud risk in granting immediate credit – the check hasn't
been charged against the payor's account, and the payee has access to the funds,
including wire transfers.

There has been a great deal of discussion lately about charging a day's availability on
cash deposits, since the bank usually doesn't have use of the money on the day of
deposit. Again, it is useful for the float manager to walk through cash deposit
processing to determine if there is a negative customer impact in delaying availability.
Cash must be made available no later than next day if it is deposited at a staffed teller
station. ATM cash deposits and night depository drops do not get the same
accommodation.

MANAGING CORPORATE CUSTOMERS IN REG CC

Reg CC applies to all transaction accounts, both consumer and corporate. But it also
recognizes the special circumstances and sophistication of corporate customers and
provides for some flexibility in managing these accounts.

1. Corporate Customers Do Not Require Annual Availability Disclosures

One major difference between corporate and consumer accounts in Reg CC is that
corporate customers are only required to receive availability disclosures at the account
opening, while consumers must receive the disclosure annually.

The language of the corporate disclosure can be written so that the corporate
availability schedules can be changed at any time and without prior notice, and that the
most current schedule is available at the branches or through a customer service
location. This would allow the flexibility you need to add or change corporate
schedules or move customers to different schedules and respond quickly to changes
in the check clearing environment.

Some banks, however, are concerned that smaller business clients, who open their
accounts at the branch, would find the availability schedule too complex, both for the
customer and the branch personnel. They prefer to give customers a disclosure
statement when the account is opened, and then update as needed. One way to meet
that need is to write a disclosure for corporate customers that covers all of the
schedules, as a maximum. Attachment D shows a disclosure edited for multiple
availability schedule disclosures, which can be used at an account opening.

2. Float Calculations Which Affect Earnings Credits are Outside the Scope of the
Regulation
The way in which float is applied or calculated on customer accounts in analysis for the
purpose of paying earning credits is separate from the availability schedule in the
regulation. Think of it this way – Reg CC schedule deals with the "withdrawability" of
funds, that is, when cash can be withdrawn or checks paid against an account.

The float schedules are part of the priced services which are part of a contractual
agreement between the bank and its corporate customers. For example, most banks
will pay checks presented against ledger balances, even though the availability

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 schedule says the items are not yet cleared. Some banks will charge an uncollected
funds fee, while only a few strict adherents will actually return a check unpaid when the
customer has uncollected funds. Nonetheless, earnings credits are only applied to
collected funds, so if a customer has checks paid against uncollected funds, the
customer's collected balance would be lower, because collected balances are
calculated by subtracting float from ledger balances. The lower collected balance
results in lower earnings credits, and ultimately higher cash management revenues.

REG CC ON THE WEB AND IN PRINT

The entire Reg is available on the web through the Board of Governors web site
(www.bog.frb.us) Click on: Regulation and Supervision, then: Regulation, then: CC, then:
GPO arrow. The direct address is :
http://www.access.gpo.gov/nara/cfr/waisidx_00/12cfr229_00.html

The commentary, which is very valuable in understanding the provisions, and the
appendices, which list the local RTs, FR, and FHLB RTs and have the model disclosure
language, can be found in the online version by going to the end of the last section §229.43,
"Checks Payable in Guam, American Samoa, and the Northern Mariana Islands". Paper
copies are available free of charge from the Board of Governors Publication office.

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ATTACHMENT A1

FOOTNOTES TO AVAILABILITY SCHEDULES

1. The first $100 of a day's deposit must be made available for either cash withdrawal or
check writing purposes at the start of the next business day (§229.10(c)(vii)).
2. Local checks must be made available for check writing day following deposit
(§229.12(b)).
3. Nonlocal checks must be made available for check writing purposes by the fifth day
following deposit (§229.12(c)).
4. $400 of the deposit must be made available for cash withdrawal no later than 5:00 p.m.
on the day specified in the schedule. This applies to the aggregate amount of deposits
that must be made available on a specified day, and is in addition to the $100 that must
be made available on the business day following deposit (§229.12(d)).
5. The remainder of the deposit must be made available for cash withdrawal at the start
of business the following day (§229.12(d)).

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ATTACHMENT A2

FOOTNOTES TO AVAILABILITY SCHEDULES

1. The first $100 of a day's deposit must be made available for either cash withdrawal or
check writing purposes at the start of the next business day (§229.10(c)(vii)).
2. Local checks must be made available for check writing day following deposit
(§229.12(b)).
3. Nonlocal checks must be made available for check writing purposes by the fifth day
following deposit (§229.12(c)).
4. $400 of the deposit must be made available for cash withdrawal no later than 5:00 p.m.
on the day specified in the schedule. This applies to the aggregate amount of deposits
that must be made available on a specified day, and is in addition to the $100 that must
be made available on the business day following deposit (§229.12(d)).
5. The remainder of the deposit must be made available for cash withdrawal at the start
of business the following day (§229.12(d)).

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ATTACHMENT A3

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ATTACHMENT B
Reg CC
Local RT List

1st District 2nd District 3rd District

Boston Windsor Locks East Rutherford Utica Office Philadelphia
0110 0111 0210 0213 0310
0112 0116 0212 0220 0311
0113 0117 0214 0223 0312
0114 0118 0215 2213 0313
0115 0119 0216 2220 0319
2110 0211* 0219 2223 0360
2112 2111 0260 2310
2113 2116 0280 2311
2114 2117 2212 2312
2115 2118 2214 2313
2119 2215 2319
2211* 2216 2360
2219
2260

4th District
Cleveland Cincinnati Pittsburgh Columbus
0410 0420 0430 0440
0412 0421 0432 0441
2410 0422 0433 0442
2412 0423 0434 2440
2420 2430 2441
2421 2432 2442
2422 2433
2423 2434

* Banks in Fairfield County, Connecticut, are members of the Federal Reserve Bank of New York and
therefore have Second District routing numbers. Their checks, however, are processed by the Windsor
Locks office. Thus, checks drawn on banks with 0211 and 2211 routing numbers would not be local checks
for Second District depositary banks.

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ATTACHMENT B, CON'T

5th District
Richmond Baltimore Charlotte Columbia SC Charleston WVa
0510 0520 0530 0532 0515
0514 0521 0531 0539 0519
2510 0522 2530 2532 2515
2514 0540 2531 2539 2519
0550
0560
0570
2520
2521
2522
2540
2550
2560
2570

6th District
Atlanta Birmingham Jacksonville Nashville New Orleans Miami
0610 0620 0630 0640 0650 0660
0611 0621 0631 0641 0651 0670
0612 0622 0632 0642 0652 2660
0613 2620 2630 2640 0653 2670
2610 2621 2631 2641 0654
2611 2622 2632 2642 0655
2612 2650
2613 2651
2652
2653
2654
2655

7th District
Chicago Detroit Des Moines Indianapolis Milwaukee
0710 0720 0730 0740 0750
0712 0724 0739 0749 0759
0719 2720 2730 2740 2750
2710 2724 2739 2749 2759
2712
2719
0711
2711

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ATTACHMENT B, CON'T

8th District
St. Louis Little Rock Louisville Memphis
0810 0820 0813 0840
0812 0829 0830 0841
0815 2820 0839 0842
0819 2829 0863 0843
0865 2813 2840
2810 2830 2841
2812 2839 2842
2815 2863 2843
2819
2865

9th District
Minneapolis Helena
0910 0920
0911 0921
0912 0929
0913 2920
0914 2921
0915 2929
0918
0919
2910
2911
2912
0960
2913
2914
2915
2918
2919
2960

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ATTACHMENT B, CON'T

10th District
Kansas City Denver Oklahoma City Omaha
1010 1020 1030 1040
1011 1021 1031 1041
1012 1022 1039 1049
1019 1023 3030 3040
3010 1070 3031 3041
3011 3020 3039 3049
3012 3021
3019 3022
3023
3070

11th District
Dallas El Paso Houston San Antonio
1110 1120 1130 1140
1111 1122 1131 1149
1113 1123 3130 3140
1119 1163 3131 3149
3110 3120
3111 3122
3113 3123
3119 3163

12th District
San Francisco Los Angeles Portland Salt Lake City Seattle
1210 1220 1230 1240 1250
1211 1221 1231 1241 1251
1212 1222 1232 1242 1252
1213 1223 1233 1243 3250
3210 1224 3230 3240 3251
3211 3220 3231 3241 3252
3212 3221 3232 3242
3213 3222 3233 2343
3223
3224

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ATTACHMENT C
Next Day RT Numbers

U.S.Treasury Checks Postal Money Orders

0000 0050 5 0000 0119 3
0000 0051 8 0000 0800 2

Federal Reserve Offices Federal Home Loan Banks

0110 0001 5 0710 0030 1 0110 0053 6 0740 0101 9
0111 0048 1 0720 0029 0 0212 0639 1 0810 0091 9
0112 0048 8 0730 0033 8 0260 0973 9 0820 0125 0
0210 0120 8 0740 0020 1 0410 0291 5 0910 0091 2
0220 0026 6 0750 0012 9 0420 0091 6 1010 0091 2
0212 0400 5 0810 0004 5 0430 0143 5 1011 0194 7
0214 0950 9 0820 0013 8 0610 0876 6 1020 0603 8
0213 0500 1 0830 0059 3 0640 0091 0 1030 0362 9
0310 0004 0 0840 0003 9 0654 0348 0 1040 0019 7
0410 0001 4 0910 0008 0 0710 0450 1 1110 1083 7
0420 0043 7 0920 0026 7 0724 1338 2 1119 1083 0
0430 0030 0 1010 0004 8 0730 0091 4 1130 1750 8
0440 0050 3 1020 0019 9 1210 0070 1
0510 0003 3 1030 0024 0 1211 3994 4
0520 0027 8 1040 0012 6 1222 4014 6
0530 0020 6 1110 0003 8 1250 0050 3
0539 0008 9 1120 0001 1
0519 0002 3 1130 0004 9
0610 0014 6 1140 0072 1
0620 0019 0 1210 0037 4
0630 0019 9 1220 0016 6
0640 0010 1 1230 0001 3
0650 0021 0 1240 0031 3
0660 0010 9 1250 0001 1

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ATTACHMENT D

Sample Disclosure Language for Banks with Multiple Availability Schedules

Maximum Hold Banks

In order to ensure that we receive final payment of the deposits you make to your account,
our policy is to delay the availability of funds from your cash and check deposits. During the
delay, you may not withdraw the funds and we will not use the funds to pay checks that you
have written other withdrawals that you have authorized.

Other Check Deposits

Other check deposits will be made available in no more than three days after the day of
deposit. The delay for other check deposits depends on whether the check is a local or a
non-local check. To see whether a check is a local or non-local check, look at the routing
number on the check. If the check is a personal check, the routing number is the first 9 digits
of the number that appears at the bottom of the check. If the check is a business check, the
routing number is the 9-digit number in the middle of the series of numbers on the bottom of
the check. If the first four digits of the routing number appear on the following list, then we
consider the check a local check: 0110 0111 0112 0113 0114 0115 0116 0117 0118 0119 0211
2110 2111 2112 2113 2114 2115 2116 2117 2118 2119 2211
Otherwise, the check is considered a non-local check. Some checks are marked "payable
through" and have a four- or nine-digit number nearby. For these checks, use the four-digit
number or the first four digits of the nine-digit number, not the routing number on the bottom
of the check, to determine if the checks are local or non-local. Our policy is to make funds
from local and non-local checks available as follows:

Local checks. The first $100 from a deposit of local checks will be available on the first
business day after the day of your deposit. The remaining funds will be available on the
second business day after the day of your deposit. For example, if you deposit a local
check of $1,000 on a Monday, $100 of the deposit is available on Tuesday. On
Wednesday, the remaining $900 is available.

Non-local checks. The first $100 from a deposit of non-local checks will be available on
the first business day after the day of your deposit. The remaining funds will be available
no later than the third business day after the day of your deposit. For example, if you
deposit a non-local check of $1,000 on a Monday, $100 of the deposit is available is
available on Tuesday. No later than Thursday, the remaining $900 is available.

If you deposit both categories of checks, $100 from the checks will be available on the first
business day after the day of your deposit, not $100 from each category of check.

Certain other checks

We can process non-local checks drawn on financial institutions in certain areas faster than
usual. Therefore, funds from deposits of checks drawn on institutions in those areas may be
available to you more quickly. Call us if you would like a list of the routing numbers for these
institutions.

Other model disclosure statement language is available in the Regulation in Appendix C.

Understanding Reg CC | www.carreker.com | © Carreker Corporation 2002 17

 For more information about Carreker's Float Initiatives,
contact cglassman@carreker.com, 954-796-7665
or visit www.carreker.com.

Understanding Reg CC | www.carreker.com | © Carreker Corporation 2002 18