Check 21's primary contribution is the creation of the substitute check. It's a Band-Aid or stop gap measure that should eventually "go away," although IRD's will stick around as replacements for lost or destroyed items. Your relevant procedures deserve considerable review and analysis, particularly if you produce substitute checks.
It has no effect on your Reg CC disclosures regarding funds availability.
Beyond the consumer disclosures it requires for some accounts, I have difficulty making it into a policy issue, but note the recent FIL issued by the FDIC talks about updating policies. They may be more imaginative than I am or may have just stuck the reference in out of habit.
Last edited by Ken/Pegasus; 05/25/04 02:51 PM.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.