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#1806946 - 04/22/13 05:26 PM Check 21 Disclosures
lawooster Offline
Member
Joined: Jan 2006
Posts: 66
The employee that use to take care of this retired and we have auditors coming so I wanted to double check on this. At new account opening do we need to give a Check 21 disclosure? It was my understanding that we did not have to at new account opening.

Thank you

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Operations Compliance
#1806956 - 04/22/13 05:44 PM Re: Check 21 Disclosures lawooster
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Unless you provide customers a deposit account statement with enclosed paid checks (originals, substitute checks or combination), you don't need to provide disclosures when the account is opened. See Regulation CC, ยง229.57(a).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1806995 - 04/22/13 06:31 PM Re: Check 21 Disclosures lawooster
lawooster Offline
Member
Joined: Jan 2006
Posts: 66
Does that include images of checks with their statement?

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#1806997 - 04/22/13 06:34 PM Re: Check 21 Disclosures lawooster
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
No - it does not include solely images that are printed on the statements. It has to be the physical items.
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#1807008 - 04/22/13 06:54 PM Re: Check 21 Disclosures lawooster
lawooster Offline
Member
Joined: Jan 2006
Posts: 66
Thank you so much for the help

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