So model form A-9... if you have the required content and did not add anything not allowed (marketing) on the form but you made the form "pretty" to look at would that be "substantially similar" I am talking about changing font, lay out etc.

IMHO - "Substantially similar" has always referred to the information being presented and not the format in which it is provided, unless the reformatting was so dramatic it impacted the information content.

One of the things you ought NOT do in making the form look "pretty" is emphasizing information that is not emphasized on the sample form, or failing to emphasize that which the sample does emphasize.

I happen to agree with those who believe the sample form is a dud. Individual parts might address consumer feedback during the Fed's consumer research on disclosures, but the form as presented isn't a coherently designed document.

What gubberment form is? See revised GFE as being incoherent.

Hi, I have two questions:
Any special meaning to the words "every day" and "one-time" debit card transactions consistently and alternatively used thorugh out the regulation that now I should worry about?

If the bank chooses to forgo charging the telated fees can the bank at a later time begin the process of obtaining opt-ins and implementing.

Thanks