Well, "provide" is defined as: To furnish; supply; To make available; afford; To set down as a stipulation.
The act also states that no liability or penalty shall be imposed on any FI or printer for an unintentional failure to comply.
Are you going to catch every single check, no. Is it a problem if you don't, probably not. How do they order checks? Do your CSR's give them a completed order form? If so, it should be on there.
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David J Mulkerin, CRCM
All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.