Our present practice when cashing a third party item is to put our customer's account number on the back of the check in case it gets returned for any reason. This is now being questioned as a privacy issue as the check writer would have our customer's name, account number, and bank. I have searched the threads thoroughly and unable to find anything; however I know this was discussed in the past.

Does your bank use this method or have you devised another way to tie the check back to the account holder?

Thank you!

From the original FAQ in 2001:

I.3. Q. I offer consumer checking accounts. I notify my customers that, among other things, I make disclosures as permitted by law. My checking account customers deposit checks made payable to my customer but drawn on a financial institution unaffiliated with me. My practice is to write my customer's account number on the back of the deposited check to facilitate its processing. The check itself then goes to the maker's financial institution, with my customer's account number on the check. Is this a disclosure of nonpublic personal information that would be subject to opt out requirements or the prohibition against sharing account numbers?

A. No. The opt out provisions do not apply to disclosures in connection with servicing or processing a financial product or service that a consumer requests or authorizes. Nor do they apply to disclosures that are required, or are a usual, appropriate, or acceptable method in connection with settling, processing, clearing, transferring, reconciling or collecting amounts charged, debited or otherwise paid. §§ 332.14(a), 332.14(b)(2)(vi)(A). Also, because the account number is added to the check solely for use in processing the check and is not used in connection with marketing by a third party, this disclosure is not prohibited by the ban on disclosing account numbers for marketing purposes. § 332.12.

Thank you, Randy, for the speedy reply.