Is Disclosure of the Routing Numbers Required?

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Question:

Under Reg CC does the Bank have to disclose routing numbers for local or non-local checks? We disclose the Funds Availability disclosure. Are the routing numbers disclosed just for convenience to the customer?

Answer:

Including the routing numbers in your disclosure is one way to inform customers how to distinguish local from non-local checks if your policy is to impose holds on deposited local and non-local checks up to the legal limits included in section 229.12 of the regulation. You are required to disclose how to make the distinction. If you can describe how without use of the routing number list, you certainly may do so. Proper and accurate use of model form C-4, however, will ensure compliance with this detail.

First published on BankersOnline.com 1/23/06