If you implement early, you won't incur liability except for the possibility that you will be making funds available sooner than required and you might have to eat a bad check here and there. But you won't get into other legal hassles.
One caution: When you implement (early or when required), your bank will need to notify consumer depositors of the change within 30 days after you make the change, if you place holds to statutory limits on all deposits. The table from Model Disclosure Form C-4 will have to be updated.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8