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#1319377 - 01/06/10 10:39 PM Reg CC & Check 21
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
With updating our Reg CC policy, because of the current changes, I'm wondering if Check 21 should be included. I realize it is Part D...but I'm not sure if I need to have a section about it right in the policy.

I do realize this is "old" stuff but I just took this over and realized the last person in charge of this didn't include anything.

Thank you for any help.

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#1319550 - 01/07/10 02:43 PM Re: Reg CC & Check 21 bsarockstar
zitch70 Offline
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Joined: Apr 2001
Posts: 331
Edinburg, Texas
I did not have the Check 21 stuff in the Reg CC policy a couple of years ago, and the inferinal auditors wrote it up as a violation. So I now have it in there.

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#1319582 - 01/07/10 03:07 PM Re: Reg CC & Check 21 zitch70
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,912
Galveston, TX
Unless you are delivering substitute checks in the actual statements, the disclosure is not required. If you truncate items or only provide images that finding was wrong.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1320956 - 01/08/10 04:39 PM Re: Reg CC & Check 21 rlcarey
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
rlcarey - so I don't need it in my Reg CC policy since we truncate? Or did you mean I don't have to give a customer a disclosure on Check 21 if we truncate?

Thank you.

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#1320992 - 01/08/10 05:00 PM Re: Reg CC & Check 21 bsarockstar
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,912
Galveston, TX
If you truncate all items (meaning they will not receive actual items in their periodic statements) a Check 21 disclosure is not required at account opening. You will still be required to provide a Check 21 disclosure anytime you provide a customer with a substitute check, i.e., returned items.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1321022 - 01/08/10 05:19 PM Re: Reg CC & Check 21 rlcarey
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
Thanks for that clarification, but I also wanted to know if in the Bank's Reg CC Policy we need to have a section on Check 21.

For the discosure part, we are doing that correctly.

Happy Friday and thank you again!

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#1321061 - 01/08/10 05:52 PM Re: Reg CC & Check 21 bsarockstar
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,912
Galveston, TX
While Check 21 is part of Reg. CC, it is unrelated to your Funds Availability Policy disclosure.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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