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Can we operate on a funds good & settled model? Please clarify steps of responsibility in the flow of funds.

As per the CFPB (Consumer Finance Protection Bureau) and the way state regulators would look at this, they would like the funds to be released only after the payout party has been paid, i.e. the beneficiary has been paid.

This is why pre-funding is used.

The license holder holds back on the funds, till such time that proof of delivery is provided for by the payout party. The funds good and settled model is already in play, as no credit is being extended by the solution provider (i.e. license holder) to you, and only the funds that are good and settled are pushed into your account, after proof of payment has been provided.




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