Forgive me if this seems redundant, but I did run a search and am still confused.

Please let me know if I am correct in this thinking:
There are 3 disclosures to be given; 1) one time to established consumer customers who receive checks 2) to new consumer accounts who will receive checks and 3) "event" notices, given when a subsititute check is given.

I saw the safe harbor wording for notice 3). But what about 1) and 2)? Can those both be the same form? What model numbers would cover those?

#1 and #2 will depend on whether you currently provide physical items back in the customer statement.

If the answer is yes to #1, you will be required to provide a notice to your customer no later than the first statement cycle after the effective date. If you will continue to provide checks back to customers in their statement you will have to disclose (#2) for all new customers going forward (after Oct. 28).

If you are an image bank and do not (and will not) send back original items in a statement, you are not required to notify the customer prior to regulation taking effect.

Your event notice (#3) will be required each time a customer requests an original item and receives a substitute check or if an substitute check is provided to a customer (in a return item situation).

As for the language for #1 and #2, I would refer to Appendix C5-A of Reg. CC.

To my knowledge, these notices are identical. We are using the model language and giving the same notice to customers in any of the three situations you described:

1. With their October statements if the customer recieves their original checks back;
2. To any new customer who opens an account and asks to recieve their original checks back
3. With an event such as a returned deposited item that is a substitute check or if a customer requests an original substitute check.

All three - Same notice. Same words. BC

Nanwa,
As Bear Collector indicates, there is only one content requirement. One model dislcosure, C-5A, fulfils that content requirement. There are three timing requirements.

Thanx for the clarification. The printing companies sent several options, one with the exact 5-A wording and the other stuff sounding more general, more educational, and I wasn't sure if there were more than one disclosure.