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ASARPAs Soon As Reasonably Possible
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If the payee is unable to determine, at the time of the authorization, whether a credit or debit card number is involved, and later finds that the card used is a debit card, the payee must obtain a written and signed or (where appropriate) a similarly authenticated authorization as soon as reasonably possible, or cease debiting the consumer's account.
Brokers should complete their efforts to comply with the JGTRRA as soon as reasonably possible for calendar-year 2003 and, to the extent reasonably possible, to comply with their reporting responsibilities in a manner consistent with JGTRRA for payments in lieu of dividends for calendar-year 2003.
In either event, the notice must be given as soon as reasonably possible.