Is is necessary to just have the UCC Article 4A disclosures at the New Account opening or should it also be included in the annual disclosures also?

To which UCC-4A disclosures are you specifically referring?

Sorry, I'm viewing a recent ACH audit and am reviewing the question of "Have the following UCC Article 4A disclosures been represented to companies AND consumers receiving "wholesale credits" entries". This would include Provisional Payment Disclosure, Notice Disclosure and Choice of Law Disclosure.

does anyone place the UCC 4A disclosures on their annual disclosres they mail out to customers or just give them out when they open their account?

We have these disclosures on the last page of a customers statement.

I'm currently doing an audit and I can't find this disclosure at all. It is not on the account agreement nor is it on the customer's statement. Any other place it may be?

Our customers are provided a separate informational sheet on UCC4A upon account opening and Originators receive it again at Agreement discussions.

Are you an RDFI or an ODFI or both?

As an RDFI (we receive SEC codes CCD or CTX) our "disclosures" are on the terms and conditions provided at account opening. As an ODFI (we originate CCD or CTX credits on behalf of our Originators) the "disclosures" are in the ACH Origination Agreement.