Reg E is skewed toward's consumer protection and not bank protection, so even if the customer writes his/her PIN on the card itself, that is not a reason that a bank can use to refuse a Reg E claim. (Note if the transaction is a VISA or Mastercard debit transaction, the customer would not get the $-0- liability in that situation but you still have the $50 liability limit.)
Having said that, there is nothing in Regulation E or any other regulation that says you must offer access devices or maintain an account for anyone.
Most banks I know have a variation on three-strikes-you're out rule (or one strike or two strikes) and if they feel the customer is negligent in handling the card, they will refuse to issue another card, and some will simply close the account(s.)
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'