Funds Availability Disclosure-Add to the Model

Posted By: Likes to Comply

Funds Availability Disclosure-Add to the Model - 12/13/13 09:59 PM

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?
Posted By: rlcarey

Re: Funds Availability Disclosure-Add to the Model - 12/14/13 04:51 AM

I think it is aimed at IATs.
Posted By: Elwood P. Dowd

Re: Funds Availability Disclosure-Add to the Model - 12/14/13 11:04 AM

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.