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NACHA IAT Question of the Week

Wednesday, December 2, 2009

Question:
If my payroll needs to be sent as IAT, could my employees' funds availability be affected?

Answer:
Yes, for two reasons: (1) unlike PPD, there is no requirement that IAT credit entries that are made available to an RDFI by its ACH Operator by 5:00 p.m. on the banking day prior to the Settlement Date be made available to the Receiver at the opening of business on the Settlement Date. Cleared IAT entries must be available no later than the Settlement Date of the entry, but funds are not required to be available at opening of business; and (2) if the IAT transaction were found to be suspect during the OFAC review, the transaction must be held until the issue is resolved and the item is cleared or identified as an actual OFAC violation. 

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