We have pre-existing charge-offs on the books that are old. We do not charge additional fees and interest, but we haven't sent a final periodic statement notifying them of the "Suspension of Statements and Notice of Charge Off..." status, and we are outside the 309 days of charge off/last periodic statement.

We don't have to start sending them statements again, do we? Any formal guidance someone can direct me to read?

These are seconds and we do not typically foreclose them.

There may be a technical argument for having to send a final charge off statement, but practically I'd probably not do that and have my argument prepared for an examiner in case it comes up. I think the fact that the loans were already charged off well in advance of the rule change is a pretty strong argument. Keep in mind this also only applies to closed-end consumer credit (1-4 family) secured by a dwelling. If that's not your loan types, you may not have to worry a out this.