I regret to inform you that you consultant is mistaken. The receipt must be given at time of payment, which means when you get paid or get permission to charge the Sender's account.
Tell the consultant to read section 1005.31(e)(2) and comment 31(e)-2 of the regulation.
Perhaps I should bill him or her for this information.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8