Answer:
The institution needs to start with the model notice included in Appendix to the regulation, make the choices indicated in the model by bracketed text, clean up a little of the verbiage (the model verbiage doesn't flow well if one or the other option is selected in a few places) and then make whatever tweaks are needed to address local practice. It's a task that bank counsel should assist with, although counsel should not be allowed to make heavy revisions in the model text.
First published on BankersOnline.com 5/30/11