On January 10 of last year the OCC sent a letter to IBAT opining that payoffs and VODs were exceptions under 40.14, "necessary to effect, enforce or administer a transaction".
The bank still has to verify in some way, that the request is authentic. Mcarollo is doing that to a high degree.
Opinions stated are not necessarily that of my employer.
[This message has been edited by Andy Z (edited 02-02-2002).]