[Hock_]

[Same caveat as my "Summary post" -- this should not be considered legal advice]

Having re-read the statute with a clearer head, I am now much more comfortable in predicting that financial institutions will NOT do anything to stop transactions until the Fed has promulgated its regs. The Act does not place any obligations on financial institutions other than those regs; the prohibition is on the parties "accepting" the transactions -- i.e., the sites. Moreover, the limitation on liability for financial institutions in s. 5364(d) is in part (subpart 3) premised on following the regs, so financial institutions could actually be exposing themselves to liability if they block "clean" transactions before the regs are finalized.

And I think it will likely take at least 270 days for regs to get done.

Bottom line: No run on the banks necessary; we probably all have at least 270 days, at least as far as moving money is concerned.