Check 21 notices to ALL accounts?

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Question:

We are getting ready to send out our notices for Check 21 and are alittle confused. It states that it affects ALL types of deposit accounts . We currently have the following products:<ul><li>Money Market Account<li>Super Now Accounts<li>Statement Savings<li>Regular Checking<li>Time Accounts<li>Christmas Clubs</li></ul>Are we required to send to all?

Answer:

Although Check 21 applies to all deposit accounts, the advance consumer familiarity disclosure only needs to be sent to consumer accounts for which the bank sends back paid checks with the periodic statement.

From your list, my guess is that you don't send checks back on Club Accounts, Time Accounts, or Statement Savings. You may send back checks on your MMDAs. You are more likely to be sending checks back on your NOW and checking accounts.

You are free to send out informational material to any or all of your accounts. But you are only required to inform the customers who get paid checks back. After your "advance" disclosures, you'll need to provide disclosures to any consumer to whom you provide a substitute check.

First published on BankersOnline.com 10/25/04