Skip to content
BOL Conferences

Thread Options
#546411 - 05/11/06 03:22 PM Check Conversion Disclosure.
complianceman Offline
Platinum Poster
complianceman
Joined: Mar 2005
Posts: 687
New Albany, IN
The bank is going to start converting check payments for loans into ACH transactions. It is my understanding that the affected customers must Opt-In to check conversion before the bank can start this activity. Does anyone have any guidance on this? I do have a disclosure available to send to all affected customers but must they sign a disclosure and send it in?
_________________________
The opinion stated here is what it is, My Opinion.

Return to Top
Operations Compliance
#546412 - 05/11/06 04:07 PM Re: Check Conversion Disclosure.
StevenD Offline
Gold Star
StevenD
Joined: Nov 2000
Posts: 489
KY
I think if you 'bill' for each payment, beginning 01/01/07 you have to send a disclosure with each bill. See the Regulation E final rule that was issued on 12/30/05.

http://www.federalreserve.gov/boarddocs/press/bcreg/2005/20051230/attachment.pdf
_________________________
Opinion expressed are my own and not necessarily those of my employer.

Return to Top
#546413 - 05/11/06 06:45 PM Re: Check Conversion Disclosure.
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Reg E requires a disclosure in or on each bill. If you use a coupon book, you only need one disclosure, printed on the front cover (inside or outside).
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z, John Burnett