[rcooper]

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?

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[rcooper]

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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