While I agree that a separate piece is more clear and conspicuous, that doesn't mean it will be read.
One thing I will add, if you allow an opt-out, make sure they can opt-out without returning a piece of their statement with other data they have to be able to keep. The initial draft of our notice would have required the customer to complete and detach the last page of their notice. Since that also meant they'd lose the last page of text, I felt that took away their ability to retain the notice. I had mixed replies when I asked about this, but will hold that it is inappropriate. It is the same premise as requiring an ATM customer to surrender their receipt to enter a drawing.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell