Certegy (cr card processor) began putting the notice on the back of their cr card stmts in June.

I have the same question. We do report our overdrawn accounts to Chexsystems. We use Chexsystems to verify ID on new members and to check if they have any closed accounts at other institutions. If they do and we do not open an account because of the information that we received from Chexsystems we give them a notice ( sort of like of an Adverse Action Notice) telling them that we can't opened the account due the negative information.It refers them to Chexsystems. We do this to comply with Reg B.

Our thoughts are since we are reporting negative information to a credit reporting agency regarding their deposit account we should include FACT disclosure in the collections letters for overdrawn accounts.

I have come to the conclusion that reporting negative information to ChexSystems WILL trigger the need for the notice.

Now......how to comply to these? What are some of you thinking about doing? Maybe statement stuffers, combining with privacy notices, etc?

We are including it on our collection letters (10 day and right to cue)for both past due loan and overdrawn deposit accounts.

We are checking on including language on NSF/OD notices.

Sorry, that Anon was me....I got a new computer and was not logged in.

Ted,
You mentioned the clear and conspicuous requirement. The summary to the Fed's Final Rule mentions that the institution must provide a clear and conspicuous notice, but I don't find that anywhere in Reg. V. Is there some cross-reference to a clear and conspicuous standard that I am missing?

Please disregard my previous post.

Am I reading this correctly? From Ted Dreyer's article dated June 204: You only need to give one notice per transaction, loan, account or customer and may submit additional negative information thereafter without giving a new notice. So I do a one time mass mailing (or stmt stuffer, etc.) prior to 12-2004 with the language in Model B-1 and I'm covered? Then I would need to add the Model B-1 notice to my new account / loan / visa / applications?
OR
I ignore the current customers and just start adding the wording to all the past due notices we send.

Yes, except that for the second option you would need to make sure that the only negative information you share results from past due payments and that they go to all covered relationships, lending and deposit.

Option 2 requires a little more work, but less cost than a dedicated mailing. Your infrastructure and customer counts will influence this.