I am referring to the answer given to the question on Day 13. The answer stated that you must send the disclosure to a consumer customer who receives paid original checks or paid substitute checks with his or her periodic account statement. Why must you give a disclosure if they receive only paid original checks and no substitute checks since they would have no rights? We are in the process of converting to imaging but depending on the conversion date, the customer may receive one statement in the beginning that includes both checks and images until they will receive only images. We were going to include the disclosures only to those customers that have a substitute check in their statement as opposed to those who may only have original checks and images. We were hoping to start imaging in time to avoid all this but are not sure that is possible.

The simple answer is "Because that's the way the rule reads, unfortunately." If the customer receives EITHER paid original checks or paid substitute checks, the one-time notice for consumers is triggered.