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#2252307 - 04/13/21 05:17 PM Check 21 Substitute Check Notice
ckme Offline
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ckme
Joined: Sep 2002
Posts: 256
Is there any issue providing the C5A notice to business account holders who get a returned substitute check?

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Deposits and Payments
#2252392 - 04/15/21 12:46 PM Re: Check 21 Substitute Check Notice ckme
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,699
229.57 applies to consumers. If you provide the C5A notice referenced in this section to business account holders, it probably won't hurt as long you do what the disclosure says you will do (and provide the customer the rights the disclosure says they have). That said, this is more of a legal question (contract issue) than a compliance question so you may want to run it by legal counsel.
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#2302137 - 10/01/24 02:29 PM Re: Check 21 Substitute Check Notice ckme
Luv2run Offline
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Joined: Jan 2015
Posts: 697
If the original notice has a mailing address with a PO BOX that is to be discontinued, would an updated notice need to go out to the customer if our statement has a notice on the back with the new address for any error resolution?
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#2302156 - 10/01/24 06:46 PM Re: Check 21 Substitute Check Notice ckme
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,239
Galveston, TX
You deliver actual substitute checks with your account statements?
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#2302178 - 10/02/24 12:50 PM Re: Check 21 Substitute Check Notice ckme
Luv2run Offline
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Posts: 697
No, we do not.
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#2302181 - 10/02/24 01:19 PM Re: Check 21 Substitute Check Notice ckme
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,239
Galveston, TX
Then I am confused as to why you would be giving a consumer such a disclosure, as you only have to provide it when delivering substitute checks to them. If you deliver substitute checks during the returned check process, that disclosure must accompany that delivery every time.
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#2302207 - 10/03/24 02:43 AM Re: Check 21 Substitute Check Notice ckme
John_Burnett Offline
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John_Burnett
Joined: Feb 2013
Posts: 551
Cape Cod
Delivering substitute checks to customers may have been done in the early years of Check 21, but the virtually complete conversion to electronic check clearing has all but eliminated the practice.
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