Are Check 21 Disclosures required to be given at account opening if no checks are ever returned to the customer? In the instance where there is a returned check on a consumer account, a disclosure is sent at that time.

No, the disclosure does not need to be provided at account opening. 229.57 differentiates providing disclosures prior to the first periodic statement if substitute checks are included with statements or for the "occasional" return of a substitute check.

Thank you.