25. With respect to the notification that should be sent to all of a participant's commercial customers that restricted transactions are prohibited from being processed through the account or relationship, is a participant required to send a notice for each applicable account or a single notice per relationship sufficient?

The final rule is silent on this issue. The core requirement in §.6(b)(3) is simply that "the participant notifies all of its commercial customers…." We will try to get clarification from the agencies regarding this question.

26. Is this notice only required one-time as of the compliance effective date of this regulation to any existing commercial customers at that time or should a non-exempt participant send this notice on an ongoing basis (e.g. annually)?

This notice is required only once.

27. Which commercial customers are required to be sent this notice, commercial customers in effect as of 1/19/09 or as of 12/1/09?

Is a financial institution required to send any periodic notices to its existing customers related to this Regulation?

This one time notice would apply to any commercial customers that were not subject to the UIGEA due diligence process when they opened an account. If the bank implements these requirements on 12/1/2009, then it would apply to all commercial accounts opened on 11/30/2009 or earlier.

It may also be prudent, going forward from the compliance date of the final rule, that a bank should provide notification (one time) to new commercial customers.

This going-forward notification need not be a "notice." It could be a provision within the account terms. See discussion on page 69393 of FR notice.

There is no requirement that this notice be sent more than one time to commercial customers.