The information I've heard is that the extension is granted automatically upon filing of the extension letter, no questions asked. If you've read the ABA/NACHA white paper, you know that they have raised some issues that will have to be addressed as far as how HIPAA applies to banks. Word on the street is that there won't be a reply to the white paper before 1st quarter next year. I feel any bank who even has the slightest question of whether this applies to them should file the extension letter and then wait for more interpretation.
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--A bad day at sea is better than a good day at work.