Our vendor adds a couple paragraphs to the combined disclosure that I'm not sure are allowed. One paragraph essentially warns the customer that the bank relies on the information given to us and that giving us incorrect information could result in money being sent to the wrong account and the money "may not be recovered." The second additional paragraph explains what "date available" means and says that it reflects that delivery may take longer under some circumstances but that in most cases funds are available sooner. I know we can disclose that funds may be available earlier, but I'm not sure about the rest of it. 1005.31(c)(4) says disclosures can only contain information that is "directly related" and the information in these paragraphs is not listed in the Commentary as directly related.

Does anyone know if this additional information is permissible?

If you put it on the back of the disclosure form, you're golden. Understand that the weasel wording about the date available won't buy you a pass on the error resolution process if the funds are late in arriving. I suggest you make your delivery time calculation generous to avoid late deliveries as much as you can. But once you have history that helps pin down delivery time, you should use it.

Thanks, John. Unfortunately, the additional information is on the front of the disclosure as the first and last paragraph. I'm not even sure we have the ability to change it, but I at least wanted to know for sure if it's permissible to have it there.

It can be on the same side of the form if clearly separated. Review comment 31(c)(4).

Well, it is segregated, but the type of information in those two paragraphs is not what's listed in comment 31(4)(c)(2) (examples of "directly related") so I wasn't even sure it could be on the disclosure even if it's segregated.

It can be, as long as it is set apart from the required stuff.

Thanks, John - It's definitely segregated. I appreciate your help.