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#1371239 - 04/08/10 03:36 PM Reg GG certification
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,087
South
Do we need a separate certification form for Reg GG or can we just drop the language into our terms and conditions agreement?

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General Discussion
#1372055 - 04/09/10 05:49 PM Re: Reg GG certification beegee
SSBStephanie Offline
Junior Member
Joined: Apr 2010
Posts: 31
Iowa
It can be put into the deposit account agreement for new accounts.

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#1372078 - 04/09/10 06:05 PM Re: Reg GG certification SSBStephanie
homestar Offline
Diamond Poster
Joined: Feb 2001
Posts: 2,245
US of A
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.
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#1372093 - 04/09/10 06:14 PM Re: Reg GG certification beegee
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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? wink
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#1372203 - 04/09/10 07:04 PM Re: Reg GG certification Elwood P. Dowd
Soccer Offline
Platinum Poster
Joined: Jan 2010
Posts: 995
Utopia
Where in the Reg can I find the disclosure requirements for consumers?
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#1372341 - 04/09/10 09:10 PM Re: Reg GG certification Soccer
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Regulation GG does not require anything that could be classified as a disclosure for consumers.
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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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#1374778 - 04/15/10 06:10 PM Re: Reg GG certification Elwood P. Dowd
CRCM2010 Offline
Member
CRCM2010
Joined: Aug 2008
Posts: 67
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?

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#1374847 - 04/15/10 07:08 PM Re: Reg GG certification CRCM2010
MyBrainHurts Offline
Platinum Poster
Joined: Feb 2010
Posts: 960
Illinois
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.
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