Opinion only: Delivering the FinCEN pamphlet ought to be a significant event. If you're delivering it, you probably want the customer to read it, and it's often handed out by tellers in some banks when a customer balks at a CTR or starts down the slippery slope to structuring, along with a "Here's some information we think you might find [interesting/helpful/makes you wake up and smell the coffee], Mr. Jones."
That's why I'd prefer to have it available to drop into a letter or hand out on demand, rather than blend it into a combined disclosure, which tends to diminish its significance. Besides, it's not a disclosure, and I wouldn't want it confused with a disclosure.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8