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#1253808 - 09/21/09 05:28 PM Reg GG notice to customers
ozzie Offline
100 Club
Joined: Jun 2003
Posts: 155
Would anyone be willing to share the wording of the notice they are going to give to all existing commercial customers for Reg GG, Unlawful Internet Gambling. Your help would be greatly appreciated. Thanks

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Operations Compliance
#1253882 - 09/21/09 06:25 PM Re: Reg GG notice to customers ozzie
ABrown Offline
Gold Star
Joined: May 2001
Posts: 279
Texas
UNLAWFUL INTERNET GAMBLING NOTICE: Restricted transactions as defined in Federal Reserve Regulation GG are prohibited from being processed through this account or relationship. Restricted transactions generally include, but are not limited to, those in which credit, electronic fund transfers, checks, or drafts are knowingly accepted by gambling businesses in connection with the participation by others in unlawful Internet gambling.

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#1254015 - 09/21/09 08:05 PM Re: Reg GG notice to customers ozzie
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If you are determined, you will find another sample in this thread @ #1244360. There are no model forms.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1254035 - 09/21/09 08:18 PM Re: Reg GG notice to customers Elwood P. Dowd
Sheldon Hendrix Offline
Diamond Poster
Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
I read that the notice does not have to be "mailed" to existing commercial customers to be in compliance. The ABA outline of the Reg. says:

Quote:
The final rule requires that banks communicate to their commercial customers that restricted transactions are prohibited under UIGEA. However, the regulation is flexible regarding how the communication is made. It could be made through a revised commercial account agreement for new customers, via a notice sent to established commercial customers, or possibly even through some other methods including even a notice on the bank’s web site as long as the commercial account holders are reasonably likely to receive it. Banks are not required to update account agreements or provide notice with a periodic statement to comply with this UIGEA requirement.


Is anybody else thinking about possibly posting on their website, or going another direction besides mailing?

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#1254050 - 09/21/09 08:31 PM Re: Reg GG notice to customers Sheldon Hendrix
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Please compare the paragraph you quote with this excerpt from the supplementary information accompanying the final regulation:

...the final rule provides that a participant could notify all of its commercial customers that restricted transactions are prohibited through a term in the commercial customer agreement, a simple notice sent to the customer, or through some other method.

Whoever wrote your paragraph has added the language suggesting that publication on a web site might be compliant. That is an expression of a personal opinion for which there is no published support.

My personal opinion is that simply publishing the verbiage on a web site would not even be treated as an attempt at compliance.

Now, if you could conjure up a mechanism where commercial customers logging on would have to acknowledge receipt of the notice to clear their screens, track who had done so...
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1254121 - 09/21/09 09:17 PM Re: Reg GG notice to customers Elwood P. Dowd
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
This requirement screams "statement notice" for current customers and a paragraph in your commercial business account agreement for new ones.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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