The fast tracked regulation as currently offered reads as:

B. Notwithstanding the provisions of subsection A of 18 VAC 25-21-150, for proceeds which are paid via credit card, the payment of such proceeds from the credit card issuer shall be deposited into an auction escrow account upon receipt from the credit card issuer.

I propose that it be amended to read as follows to include all electronic fund transfers (EFT) and not just credit cards but also debit cards, check cards, check scans, wire transfers, etc.  The current proposed regulation severely limits it authority to only credit card transactions. The suggested language that would correct the deficiency follows:

B. Notwithstanding the provisions of subsection A of 18 VAC 25-21-150, for proceeds which are paid via credit card, debit card, check card, or any other electronic funds transfer (EFT) method shall be deposited into an auction escrow account upon receipt from the originating source.

Respectfully submitted,

Frank W. MaGann, President

VCPM AUCTIONS LLC  VAF #2908000679