We are converting from a state bank to a national bank. Do we still need to include a “starting date” on the face of our checks now that we are a national bank?

No you are not required to include the date a deposit account was opened (“starting date”) on each check. The Illinois Consumer Deposit Account Act and the Check Printer and Check Number Act previously required banks to clearly display the month and year in which a deposit account was opened on the face of each check. However, in 2014, the both laws were amended to remove this requirement.

In addition, we are not aware of any federal law requiring national banks to print a deposit account’s starting date on the face of all checks.

For resources related to our guidance, please see:

  • Consumer Deposit Account Act, 205 ILCS 605/2 (“For all consumer-deposit accounts opened after January 1, 1982, all new checks, drafts, or orders drawn on financial institution accounts shall clearly display on the face of each check, draft, or order a number. Each check, draft, or similar order shall be numbered consecutively. This Section shall not apply to temporary checks, drafts, or orders of withdrawal provided by financial institutions upon the opening of a consumer deposit account.”)
  • Check Printer and Check Number Act, 205 ILCS 690/10 (“Identification and numbering of consumer – deposit account. For all consumer-deposit accounts opened after January 1, 1993, all new checks, drafts, or orders designed to be drawn on financial institution accounts shall clearly display on the face of each check, draft, or order a number. Each check, draft, or similar order shall be numbered consecutively. This Section shall not apply to temporary checks, drafts, or orders of withdrawal provided by financial institutions upon the opening of a consumer deposit account.”)
  • Public Act 098-0950 (removing the requirement to include the month and year a consumer deposit account was opened on the face of each check)