12 CFR 221.102 – Application to committed credit where funds are disbursed thereafter
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The Board has concluded that the date a commitment to extend credit becomes binding should be regarded as the date when the credit is extended, since:
(a) On that date the parties should be aware of law and facts surrounding the transaction; and
(b) Generally, the date of contract is controlling for purposes of margin regulations and Federal securities law, regardless of the delivery of cash or securities.