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#1528822 - 03/30/11 03:16 PM CHECK 21
t0dd Offline
100 Club
Joined: Sep 2004
Posts: 229
Most all of the new accounts we currently open, the checks written on those accounts are not returned in the statements and are held in safe keeping and thus we do not provide a Substitute Check Policy Disclosure. My question is when must we provide this disclosure?

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Operations Compliance
#1528830 - 03/30/11 03:26 PM Re: CHECK 21 t0dd
BrianC Offline
Power Poster
Joined: Nov 2004
Posts: 6,724
Once instance if which I am aware is when you receive a substitute check for a Fed return item (i.e. a check you customer has deposited to their account returned NSF, Stop Payment, Account Closed, etc.)

Include the notice with the substitute check and debit advice you send your customer.
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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#1528921 - 03/30/11 05:34 PM Re: CHECK 21 BrianC
Bob The Banker Offline
Platinum Poster
Bob The Banker
Joined: May 2010
Posts: 958
The disclosure requirements can be found in Reg CC, Subpart D, 229.57 Consumer Awareness:

My understanding is you must provide the disclosure any time you give a consumer a substitute check. (e.g., returned deposited check is returned to custoemr as a substitute check)

Also, if the customer receives paid originals OR paid substitute checks back with their statements, the disclosure would need to be provided at account opening.

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