Reg E says we have to make funds available at the time funds are received. However, under the upcoming IAT rules, we will need to hold funds until an OFAC alert has been verified. Doesn't this present a funds availability issue? Or is there some allowance for a hold to be placed in the case of an OFAC hit?

This is so weird - we just had a meeting about this and the same question was brought up. I hope you get some good answers for both of us.

What I told them was OFAC trumps Reg E <grin>.

LOL- Our AML/BSA people said the same thing!

Is IAT covered in a forum on here somewhere? I can't find it, but could have missed it.