If a business account was opened prior to the June 1st compliance date of the Unlawful Internet Gambling Act and the bsuiness would like to have some of the signer changed, is it necessary to disclose the prohibitions of the Act now?

Were you not required to notify existing customers when this went into place?

I do believe that you were required to disclose this to your existing commercial customers.

Yes, you were required to do so. When the regulation went into effect we sent a mailing out to all business customers; new customers got the revised account agreement with the Reg GG language in it.

Ok, that makes sense. Thanks! Another question though. Say we have a new business open a checking account, new to the bank. We disclose per Reg GG. The same business opens another account say a sav account, at a later time, must we re-disclose? Does this diclosure requirement need to be done per business account or per customer?

I'm not sure if there is a specific requirement, but we are doing it per account. It is in our account disclosure agreement and also on the Customer Due Diligence worksheet that we complete for every new business account.

That is what we have been practicing too. Per account not customer. My interpretation is just that, per account. So I was wondering what others were doing. Thanks! No plans to change at this point.

Do we have to give a notice to Commercial customers that open a CD? It is not a transaction account so not sure why we would give them one.

We are only giving the certification to transaction account customers.