Who in your institution is responsible for drafting the communications to customers? Compliance? Marketing? Has anyone done so yet and if so, are you willing to share?

We wrote an article for our customer newsletter that went out last month. As far as who should be handling communications, I think it needs to be a collective effort across several different areas. In my writing, I found that Check 21 is one of the most difficult topics to write to a non-banker audience, because it is so jargon and acronym laden. Fortunately, I was able to get help from several people here who think like customers and are able to translate bankese to English effectively.

I agree with Jac; you want a collective effort. The technical points need to be addressed, but in a way that the reader, at whatever level you write to, can understand. I think we used to say it had to be understandable by a 9th grader. And Marketing may consider the layout as well as combining it with other mailers you may have going out and factoring in postage.

Several skillsets apply here.

I am responsible - Marketing. So far, I have sent out a letter to the 1,000 customers (with a free check offer if they convert to images now) who receive hard copy checks to give them a heads up. This month, I am sending them an educational brochure from ABA. I had a section in my newsletter which goes to all c/a customers last month, and I have this on our web site: Check 21 on web site

Thanks for the link.

So you are sending information to your consumer customers before the required disclosure spelled out in 229.57?

Yes - even though the official "safe harbor" language will be the official notification, it is our philosophy to start preparing customers with general information well in advance - we did the same thing for Y2K. There are many vendors creating pre-safe harbor materials as preliminary customer education pieces.

Are you an imaging bank at this time?

Yes - have been for almost 10 years

Currently, about 1,000 accounts out of about 25,000. And wouldn't you know it, the average age of these accoutholders is about 119.

We are not currently an imaging bank and may not be when Check 21 becomes effective. Should we consider notification of our customers even before the required date?

Make sure you aren't going to change anything prior to 10/28 and that the final notice language has been issued. Then you are free to provide the notice anytime prior to the deadline. The proposed deadline is the first communication (statement?) with the customer after 10/28/04.

I am the compliance officer and I am looking at Check 21 for disclosure requirements; however, I am also monitoring what operations is doing about this. Making sure that strategies are planned, etc.
I do not know exactly how much regulatory scrutiny this will receive, but I always like to have my bases covered with a proactive stance.

Mentioned was a newletter. Can you give an idea of how you do this. I have not heard of this before, but it sounds like a good idea. Is this a newletter to your customers?
Thanks

Yes - every quarter, I send a one page (2-sided) newsletter to all checking customers in their statements. It's called Items of Interest and it contains short blurbs about various things, a message from the Chairman, and because it adds no postage, I use it for my annual privacy notice (and do that during the savings cycle as well, leaving me with a smaller segment who need to still get the notice) and timely things such as Check 21, etc. I also post it on our web site, so you can see what I'm talking about. Just Open Items of Interest PDF - part 1 and 2

When I open your PDF files and try to save a copy, Acrobat Reader says that the operation is not permitted. Just curious, are you setting the document properties to prevent this? This has happened with several Web PDF documents from other sites lately, and I am checking to see if my newest version of Acrobat is causing the problem, or perhaps more sites are using this limitation in the docuemnts.

I was especially thinking that your privacy policy would be available for electronic retention.

Well, our Privacy Policy Statement is on our web site separately and can be printed and/or stored, but I think we do protect our PDFs so they can't be altered and probably not saved either.