According to 216.9 (g) we can give one notice per account and count that as notice to all consumers jointly. Therfore, we should be ok if we stuff in all our checking and savings statements and send to any primary account holders who do not have a checking or savings account?

We only need to give the notice to consumers, so we do not need to send to business accounts. Do you send to sole props?

Thanks

I think you're covered. We statement stuff all consumers who receive a statement (checking, HELOCs, etc.) and all others (safe deposit box holders, car loans, etc.) get a separate mail out. We eliminate as many duplicates as our system can identify.

So you do not send to business customers?