Reg CC-Substitute Check Questions

I am trying to complete a Reg CC Audit and am totally hung up on the Substitute Check part. For one it asks if we are a reconverting bank. According to all my sources, we are not, but they were not very convincing...how do I determine, without a shadow of a doubt that we are or are not a reconverting bank? Also as far as the recredit procedure, is this something that happens rarely? I have asked for documentation from Ops and they all look at me as though I have a third eye.

Bump

Do you receive an electronic check file from Fed and then convert the file to checks to be put in your customers' statements? If you do you are a reconverting bank. If you don't reproduce the checks to a paper form you are not.

Can anyone give me some help in regards to audit procedures for Reg CC? I'm starting a compliance audit and the procedures on the OCC site don't seem current does anyone have an idea where to receive the most up to date copies? I have searched and can't seem to find anything newer.

Thanks

The only change in a while is the fact that there are no longer any local checks.

Thanks Randy: During a recent review of the program I used for FCRA it was brought to my attention that the FRB procedures, (most recent ones from their site), that I used didn't reference the affiliate marketing opt-out. Even though I acknowledged it in my report that it didn't apply to our institution. It was still placed in the review. I just don't want that to happen again.

All the statements are processed through our data center. So in house we do not produce copies of checks for statements