Is anyone currently mailing out access devices(checks or credit/debit cards) If so, can you provide me with some information about your process and the following:

The accounts are set up in a manner when a draw happens, it goes from the LOC to a "dummy" checking account. I'm not sure, other than disclosures, what is necessary and if there is anything that prohibits it. I can't find it in RegZ.

Dawn

Many banks process in this manner with a dummy checking account. It is a processing step only. Just make sure you and your card issuer are on the same page. You can't be issuing debit cards for this product. They are credit cards and fall under different rules.