Neither of those requirements specifically says the disclosures have to be on the back of the statement. In each case, there is a longer version of the disclosure, which is to be delivered to the consumer annually. Or, again in each case, there's a shorter version that is to be delivered on or with each periodic statement. You get to choose the annual or periodic notice.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8