Doug, I could not have chosen better words, so you will hear no objection from Cape Cod.
I will add an example. If your bank uses only the disclosure model form C-1 language, you don't allow for new account holds. Therefore you cannot use them. But it you use wording from a different model form (C-2, for example), you're set.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8