Answer:
There is, in my opinion, an awful lot of unnecessary paranoia about Regulation P. We have somehow elevated this regulation to undeserved primacy over some of the rules of common sense. These questions demonstrate the discomfort many bankers have with the concept of Privacy.
It is wellestablished in the Q&A about Regulation P that verification of funds to cover a check is an acceptable practice, provided the bank takes reasonable steps to verify the legitimacy of the request. The "legitimacy of the request" is the problem that has convinced some bank management to refuse to verify their customer's funds. We can argue that question at some other time and in some other place.
The check printer verification is also one that fits squarely within the exceptions in Section 216.14 of Regulation P. The customer wants checks and has chosen a printer that you don't normally deal with. If you permit that, you should be able to verify the data the customer has provided the check printer. It helps you maintain or service the consumer's account with you (Section 216.14(a)(2)). You should, of course, verify first that you're dealing with a check printer.
First published on BankersOnline.com 8/05/02
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