We send out interest earned statements for CDs, if we placed the model language on that notice would that meet the legal requirement for CDs? I know the renewal notices are required, but not sure the interest earned statement are legally required.

but not sure the interest earned statement are legally required.

They are not and IMHO, it would not meet the requirements.

If those interest earned statements are of the "grow your own" variety, they aren't legally required, so you can't use them for piggy-backing the annual notice.

And if they are of the IRS 1099-INT variety, IRS rules won't let you piggy back anything on or with them.

What about printing the notice on the back of our statement stock as a permanent feature? It would be on every deposit and loan statement the customer receives. I believe it would reach the majority of our customers but you'd still have to query for those exceptions once per year.
Any thoughts?

One of the requirements is that it must be conveyed in a clear and conspicuous manner. Statement stock language, particularly on the back, might not be clear and conspicuous.

Guess it would be ok to put the notice of availability on accts that receive periodic stmts and send the actual Privacy Notice to the rest of the customers. (safe dep box only, those with only loans etc) We're a small bank & thus do not send out loan stmts.

Ted Dreyer,

I don't know why a statement message would be considered more clear and conspicuous than permanent language on the back of a required periodic statement. I don't think customer's pay attention to anything that appears on their statements unless they are specifically looking for something.

Seems to me that putting the language on periodic statements as a permanent feature would be a simple solution. However, as others have noted, we would have to do the same thing we have always done in the past and identify those customers that do not receive statements and mail the notice to them separately.

Dolly: I'm not saying that it can't be a permanent message, but it does have to meet the clear and conspicuous standards of 12 CFR 1016.3(b). If it's done right, having a permanent message would probably be OK, but much of the statement language that I have seen is not clear and conspicuous. I'm just saying that anyone doing that should keep the regulation in mind.