I am reviewing Regulation CC. I see the section on Check 21. I obtained our check adjustment records. We are not mailing out any type of recredit letters or final resolution letters. Perhaps I am nervous for no reason that we haven't been using the model notices in Reg CC????? How do I know if it is a check 21 claim? Basically one customer has come to the bank with a complaint that a check that was not hers cleared her account. It was a different bank and totally different name on the check, but anyway, we immediately gave her credit and submitted the adjustment through fedline. There was no paper notice provided to her. Was that a check 21 claim? Should we have mailed her a letter although she was in the bank when we gave her the credit and told her we were giving her her money back?
Second scenario is one of our business customers had a check clear his account twice. A local bank had somehow processed the batch twice. he called, we gave him credit, and did a check adjustment through fedline for a duplicate. No notice or letter was sent to him but he was told he had been given credit. Was this a check 21 claim?
I didn't find the right solution from the Internet.
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