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#1878685 - 12/13/13 09:59 PM Funds Availability Disclosure-Add to the Model
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,061
In the mountains
Our Funds Availability Disclosure includes the following statement:

From time to time, we may need to temporarily suspend processing of an ACH transaction for review and verification. This may affect settlement and/or availability.

Is this action permissible? Is it appropriate to include this in this disclosure?
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#1878730 - 12/14/13 04:51 AM Re: Funds Availability Disclosure-Add to the Model Likes to Comply
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,898
Galveston, TX
I think it is aimed at IATs.
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#1878736 - 12/14/13 11:04 AM Re: Funds Availability Disclosure-Add to the Model Likes to Comply
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
As rlcarey suspected, its inclusion became a popular recommendation a few years ago when IAT's were a hot topic. As Regulation CC has nothing to do with funds availability from ACH credits, it really has no business in a Regulation CC disclosure, but saying it's wrong would be a stretch.
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