REG E states you must provide a change in term notice 21 days prior to certain types of changes such as increase and fee or greater restrictions,etc. If the change is positive and does not fall into one of the listed categories do you still need to send a change notice within a reasonable period of time but just not in advance?

We are getting ready to offer mobile banking deposit capabilities. We are trying to determine if we need to send a change notice out or just provide information when someone wants to sign up.

It would be a new service and not a change in terms:

7(a) Timing of Disclosures

1. Early disclosures.

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.