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Reg CC Hold on PPP Funds

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  • April 6, 2020 at 10:43 am EDT #31969
    rcooper
    Member

    A question we received via email:
    Our management team wants to place a permanent hold on PPP funds. If the customer contractually agrees to this on the front end, is that possible?We are just talking about the PPP loan funds deposited, which would likely be ACH deposited. I do not see any issues here, especially since the customer is agreeing to it contractually when the loan is closed. Do you?

    April 6, 2020 at 12:09 pm EDT #31970
    rcooper
    Member

    answer by Deb Crawford:
    I have not heard of “contractually” changing regulation. The regulation was put in place because of the various practices like these for banks. If the funds are coming in ACH they are available when they are received.

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