Effective June 1, 2026

Funds Availability Disclosure

This disclosure is provided pursuant to Regulation CC (12 CFR §229). It explains when funds you deposit in your Initio Treasury Account become available for withdrawal.

General policy

Our policy is to make funds from your electronic deposits (ACH, wire, RTP, FedNow, book transfers) available on the business day we receive the deposit. Funds from check deposits will generally be available no later than the second business day after the day of deposit, but in some cases we may delay availability.

Holds on certain deposits

In certain circumstances, the first $5,525 of a check deposit will be available on the next business day, with the balance available no later than the seventh business day. We may apply a longer hold if:

  • You deposit checks totaling more than $5,525 in any one day
  • You redeposit a check that has been returned unpaid
  • You have overdrawn your Account repeatedly in the last six months
  • There is an emergency, such as failure of computer or communications equipment
  • We believe a check you deposit will not be paid

Cut-off times

Business days are Monday through Friday, excluding federal holidays. The deposit cut-off time is 6:00 PM Eastern Time. Deposits received after the cut-off, on a weekend, or on a federal holiday are considered received on the next business day.

Wire transfers

Incoming domestic wires received by 5:00 PM ET are available the same business day. Outgoing wires must be initiated by 5:30 PM ET for same-day execution.

Questions? Email compliance@initiotreasury.com or write to Initio Capital, Inc., Compliance Dept., 548 Market St #95421, San Francisco, CA 94104.