When will customers, including trustees, encounter substitute checks under Check 21?
Banks are not required to convert original checks to substitute checks. However, because of the potential cost savings, it is anticipated that most banks will eventually convert original checks to substitute checks. The conversion to substitute checks is expected to be a gradual process so that after October 28, 2004, customers may receive a combination of original checks, substitute checks and check images. While banks are not required to accept images under Check 21, many banks currently have image exchange agreements and those agreements are not impacted by Check 21.