We are wanting to change our statement cycles to all drop at the same time a month but we were wondering about customers who have their social security direct deposit on the 3rd of the month. Do we become out of compliance if they don't get their statement until the end of the month - we are thinking we have to notify them within 3 days of their auto deposit and so by doing the statements on the 4th of the month we were able to do that without sending a separate notice.

Put that on your list of old wives' tales. Actually, for a brief time, that was the case. Then Regulation E was amended to allow for telephone calls to conform receipt and many banks stopped sending notices. But a lot of banks did cycle accounts with SSA payments on the 3rd or 4th of the month as a continuing convenience to customers.

My experience is that SSA recipients who called on or about the 3rd of each month did so more as a matter of social contact than a real need to confirm the repeat occurrence of something that had happened like clockwork without fail for decades.

If your Reg E disclosures tell customers they can call to confirm receipt, you've addressed the issue.

Thank you John, I wasn't sure where to start looking on that one.

When SSA direct deposit began we did set our all our SSA recipients' statements to cycle on the 4th of the month. It was pretty clever then, but would require a great deal more intricacy today because payments are issued several times during the month, not just on the 3rd.

Providing a number to call is now the easier method.