Funds Availability

Expedited Funds Availability Act of 1987 and Federal Reserve Regulation CC require all financial institutions to disclose their specific policy as to when deposited funds are available for withdrawal. This disclosure statement explains the timelines around making your funds available to you. Funds availability applies at the Pool customer profile level and across linked Pool Accounts.

Pool permits the following types of deposits:

• Direct Deposit (via ACH)

• ACH transfer from an external or linked bank account

• A2A/AFT/OCT transfer from an external debit card or credit card

• Internal transfer from a Linked Pool Account

Pool does not accept the following deposits:

• ATM deposits

• Wires

• Personal checks, cashier’s checks, money orders, foreign currency or cash

Recurring ACH transfers from linked bank accounts are treated as ACH transfers from an external or linked bank account and are subject to the same availability schedule.

Because we understand that having access to your funds is extremely important, we try our best to make any deposited funds available to you promptly. In many cases, funds are made available upon receipt, and no later than the next business day; however, availability may be subject to verification, fraud prevention, or regulatory holds as described below.

Business Day Definition. The length of the delay is counted in business days from the day of your deposit. Every day is a business day except Saturdays, Sundays, and federal holidays. If you make a deposit on a non-business day, we will consider that the deposit was made on the next business day we are open. The length of the delay varies depending on the type of deposit and is explained below.

Incoming Direct Deposits. Incoming funds from electronic direct deposits (“RDFI”), or direct deposits made through your employer or benefits provider will generally be available on the day we receive the deposit, and no later than the next business day.

Incoming Bank Transfers. Incoming transfers from other banks may not be available immediately. The time it takes for us to receive the funds can vary depending on the other bank and factors such as the amount of the transfer. Once we receive the funds, we may place a brief hold before making the money available in your account. In most cases, incoming bank transfer funds are made available within two business days after we receive them, and no later than the next business day if required by applicable law.

Incoming A2A/AFT Transfers (pending). When processing transfers from debit cards, the timing of funds availability varies depending on the bank that issues the debit card. A variety of other factors such as the size of the deposit may also influence the processing time. Incoming debit card transfers are almost always available instantly. In many cases, funds are made available promptly upon receipt; however, availability may be subject to verification, fraud prevention, or regulatory holds as described below. Certain funding methods, such as debit card transfers, are governed primarily by card network rules and Regulation E rather than Regulation CC. Availability timelines for those methods may differ.

Internal transfer from a Linked Pool Account. Internal transfers from other Pool Accounts are almost always available instantly.

Availability of Other Deposits / Your Ability to Withdraw Funds. Our policy is to make funds from your deposits available to you no later than the next day after the Bank has received the deposit. Electronic direct deposits will be available on the day we receive the deposit, and no later than the next business day. Our general policy is to make funds available as soon as practicable after receipt and no later than the next business day where required by applicable law, with a few exceptions as described in this document.

In limited circumstances, we may delay the availability of funds from an electronic deposit or restrict access to funds while we review the transaction for potential fraud, unauthorized activity, or compliance with applicable law. When this occurs, we will provide notice to you at the time the deposit is processed or no later than the next business day, explaining the reason for the delay and when the funds are expected to become available. If a deposit is later determined to be unauthorized, returned, or otherwise invalid, the funds may be reversed in accordance with applicable law and network rules. If you have questions about a delayed or reversed deposit, you may contact Pool Customer Support.