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#181068 - 04/19/04 06:35 PM Model Disclosures
Wore Out Offline
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Kentucky
When will the Fed have model disclosure language/forms available for review? I'm wanting to hold off on brochures/forms until that point just in case they add some commentary that could change the way the disclosure needs to read.
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#181069 - 04/19/04 07:32 PM Re: Model Disclosures
Retired DQ Offline
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I am under the impression that it will be at the end of July 2004.
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#181070 - 04/19/04 09:39 PM Re: Model Disclosures
Wore Out Offline
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Thanks Maria! I had heard that too, but I wanted to make sure
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#181071 - 04/19/04 11:27 PM Re: Model Disclosures
Bill Saffici Offline
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July 28 is the latest possible date that the Fed can release the changes to Regulation CC Part D, which will include the model language. There is speculation that it might be finalized as early as late May or early June, in order to provide banks ample time to implement the necessary changes.

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#181072 - 04/20/04 03:41 PM Re: Model Disclosures
IUalum Offline
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I'm looking for a model form for consumer claims for recrediting. Has anyone seen one of those? (We're not an ABA member, so I can't get one in the Check 21 Toolkit.)
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#181073 - 04/25/04 09:57 AM Re: Model Disclosures
Elwood P. Dowd Offline
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You can get a glimpse of what a model form for the "Consumer Awareness" disclosure might look like in the proposed regulations. It is included as form C-5A. It should be incorporated in the final regulations Bill describes as the same form number, but the language may be different.

usbavp
Sample disclosures for consumer claims for recrediting are also included in the proposed regulations as forms C-22 through C-25. Because the Fed was not required to develop these forms, they are not "models" in the sense that their use is deemed to constitute compliance with the regulation.

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#181074 - 04/28/04 12:07 PM Re: Model Disclosures
Elwood P. Dowd Offline
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usbavp,
It has been pointed out to me that you were probably asking about a form for the consumer to complete, not a form for responding to a consumer claim. There are no model or sample forms for a consumer to complete in the proposed regulation. It is doubtful that one will be included in the final regulation, even as as sample.

When a final regulation is issued, you will probably be bombarded by those ever-helpful forms vendors who will be anxious to sell you one. Hopefully, it is a form that you will need in very small quantities - it is yet to be seen that there will even be that many substitute checks or what percentage of those will generate claims.

Nevertheless, the form will be critical. If it is to be forwarded to another bank in support of your bank's claim, it is fair to assume the other bank will be anxious to find fault with its content and structure.
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