Do we need a separate certification form for Reg GG or can we just drop the language into our terms and conditions agreement?

It can be put into the deposit account agreement for new accounts.

You should check your account agreement. You may already have a general prohibition against the depositor from using the account to conduct illegal activity. You don't have to specifically identify illegal internet gambling.

I'm intrigued with any vendor that has incorporated this into their account opening agreements. It's one heck of a leap to conclude that any garden variety employee authorized to open or sign on a checking account is instantly capable of offering an unrelated certification of compliance with federal law on behalf of the organization.

Who would have known that?

Where in the Reg can I find the disclosure requirements for consumers?

Regulation GG does not require anything that could be classified as a disclosure for consumers.

Ken, Does Reg GG specificially require a separate policy to be created or do you think we're okay if we have added something to our Account Agreement and other agreements, such as Cash Management agreements?

Sec. 233.5 Policies and procedures required

(a) All non-exempt participants in designated payment systems shall establish and implement written policies and procedures reasonably designed to identify and block or otherwise prevent or prohibit restricted transactions.