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Background: This article is being created to inform about the resumption of M3 setoffs, which had been paused since August 31st.

Starting November 6th, M3 setoffs will resume, and any clawbacks that were pending during the pause will be processed over the coming weeks to avoid overwhelming cash flows for installers.

An M3 setoff refers to the clawback process in which any payments made to an installer for jobs not M3-approved at 271 days are deducted. If a job has not received M3 approval by this timeline, 100% of any payments made to the installer will be subject to a setoff.


Due to the two-month pause, a backlog of clawbacks has accumulated. These clawbacks will be spread out across the remainder of the year to minimize financial impact.

  • For organizations that we are parting ways with, the backlog of setoffs will not be spread out but will instead be processed in bulk.

  • Freedom Forever's catch-up setoffs are expected to remain paused until Q1 2025 and will be spread over time once resumed.

The catch-up setoffs that would have processed during the pause may pose cash flow challenges for some installers if they were all processed at once. To help mitigate this risk, the Risk team has provided a list of jobs that will be bulk set as "exempt from setoff."

  • This exemption will temporarily prevent these jobs from having clawbacks processed against them during the catch-up period.

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