We are replacing ATM only cards with check cards that will have POS capabilities. I believe based on the section below we need to provide Reg E disclosures. Would these disclosure be required in advance of issuing the cards?
Paragraph 5(a)(2)
1. One-for-one rule. In issuing a renewal or substitute access device, only one renewal or substitute device may replace a previously issued device. For example, only one new card and PIN may replace a card and PIN previously issued. A financial institution may provide additional devices at the time it issues the renewal or substitute access device, however, provided the institution complies with ยง 205.5(b). (See comment 5(b)-5.) If the replacement device or the additional device permits either fewer or additional types of electronic fund transfer services, a change-in-terms notice or new disclosures are required.