Are there any timing requirments for UCC 4A disclosures like at account opening or on an annual basis.

The customer is to receive the disclosure prior to receiving a transaction subject to Article 4A. We give the disclosure at account opening as part of our new accounts package. For customers originating transactions subject to Article 4A verbage is in the agreement. If you have not been giving the notice/disclosure you will probably need to do a mass mailing.