Section 229.16(b)(2) describes how a bank should disclose local & non-local checks.
Our bank discloses the routing numbers to which we consider local.
We mergered with a bank that is in a separate processing district. We now consider that districts item local along with our original district. (i.e., we are processing thru two districts).
Are we required to add these routing numbers to our discloser? It is not adverse to the customer and would cost a lot to re-do the disclosure and discard all the old ones.

Any suggestions?

Thank you

Your disclosure must be correct at the time it is given, so I believe you need to revise it on a go forward basis. I don't see anything that would require you to notify existing customers of the change. Nevertheless, my personal decision would be to notify them via statement messages without regard to the time frame established in the regulation for mandatory notification.

Thank you Ken.

I am getting resistance from management in relation to adding the second set of routing numbers.
They want me to show them in the regulation before they will spend any money.

Can you or anyone help me discover this?

Thank you,

Do you actually place mandatory holds on all deposits? If you are a case-by-case bank, this disclose is not required.