We have been sending check images in our deposit statements for years. Now, we are entertaining the idea of truncating the check images. Can we do this? If so, do we have to provide notice and, if so, how far in advance? Any particular regs that need to be considered?

Thanks much!

I would provide at least 30 days advance notice. This will serve as the "warning" to those individuals that rely on the images for their recordkeeping (as opposed to maintaining a check register as they should). State statutes I have seen do not require check images be provided, only a periodic list of the items that cleared the account by date, check number and amount. You will want to check your state's statutes before making a final decision.

Your customers may take to this change a little more easily if your online banking service provides links to check images. But I second everything that Brenda has suggested.

Ditto above. For those without internet access, you might also consider making it free to have images printed at the branch. I know our seniors would be furious if we stopped giving them images. They were angry enough when we stopped mailing the canceled checks.

Massachusetts banks have to either return paid checks or provide up to 25 front and back copies per year, gratis. That was the "give-up" in order to get the law here changed to allow statement truncation.