Conclusion: Reg CC - Funds Availability Disclosures

What we have just presented are the basics as to what you must include in your funds availability initial disclosure, the account holders to whom you have to give it, and the form it must take. For additional guidance, we refer you to Regulation CC, Sections 229.2, 229.10, 229.11, 229.12, 229.13, 229.15, 229.16, 229.17, and 229.19, and the Commentary to those Sections. Appendix C to the Regulation includes a number of model forms for making the initial disclosures, and we’ve referred to some of them in our discussion. However, remember that the function of the disclosure is to tell the depositor what your policy is, and whatever language you finally decide on should accurately reflect your policy. Using the model forms is proper only if they accurately reflect your policy. You should not be afraid to deviate from the model language if necessary.