We are updating our Reg. E disclosure to include mobile banking transfers. There are no extra fees with having mobile banking so there is no negative impact on the customer. Do we have to send the new disclosure out before the customers use the service or do we have so long after the service is available to send the new disclosure out since there is no negative impact?

Also, do we have to send out the entire disclosure or can we just send the section that is being added?

Thanks in advance for any help!

7(a) Timing of Disclosures

1. Early disclosures. Disclosures given by a financial institution earlier than the regulation requires (for example, when the consumer opens a checking account) need not be repeated when the consumer later enters into an agreement with a third party to initiate preauthorized transfers to or from the consumer's account, unless the terms and conditions differ from those that the institution previously disclosed. This interpretation also applies to any notice provided about one-time EFTs from a consumer's account initiated using information from the consumer's check. On the other hand, if an agreement for EFT services to be provided by an account- holding institution is directly between the consumer and the account-holding institution, disclosures must be given in close proximity to the event requiring disclosure, for example, when the consumer contracts for a new service.