If you determine it to be a separate access device, then yes, you would have to provide a disclosure to all customers that have that access device available.
Although if you are using the same password and PIN and the only difference is a mobile platform versus a desktop platform and all services they access are the same, I'm not sure why it would be a separate access device.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com