2 questions ...

1) Does the model language in Reg E for Electronic Check Conversion cover ECKs, ARCs, POPs, etc ... basically anything that starts as a check and converts to an EFT?

2) If we already mention electronic check conversion in our Reg E disclosure but want to change to the model language, would that require redisclosure to all customers?

The Fed uses "ECK" as a shorthand for electronic check conversion. The model language in Model A-2(d)(2) (updated version) covers all ECKs. That currently includes ARC and POP entries. If NACHA approves a "back office" derivative of POP entries, the BOC ("Back office conversion") entry will likely join that list.

Although seeing your exact current language would give me a firmer feel for the question, it's very likely that changing to the model language would only serve to clarify what you've already disclosed. That would not require redisclosure.

We currently say "You may pay for purchases or withdraw cash at places where a check is presented at a point-of-sale terminal or is mailed to a merchant or other payee or lockbox and later converted to an electronic fund transfer."

Does it sound like we're saying the same thing as the model language?