Anyone familiar with the requirement to do an annual PINless Debit disclosure mailing? If you are, my question is do we also have to mail out a copy of our Cardholder agreement with the disclosure? I've copied the Visa Operating Regulation section for this - see the 4th bullet point under section 6.2.A.7.b:

6.2.A.7 Non-Visa Debit Transaction Processing (Effective July 1, 2008)
6.2.A.7.a An Issuer that enables Non-Visa Debit Transaction processing on its Visa Check Card
or Visa Debit Card must ensure that all such transactions are facilitated by a PINDebit
Network.
6.2.A.7.b An Issuer that enables Non-Visa Debit Transaction processing on or after
July 1, 2008, and does not require that all such transactions be authenticated by a
PIN must:
• Clearly communicate to its Cardholders at the time of implementation of such
processing or at the time of issuance, and on an annual or more frequent basis
thereafter, that it has enabled Non-Visa Debit Transaction processing and that it
does not require that all such transactions be authenticated by a PIN
• Clearly communicate to its Cardholders the identity of the debit networks for which
such transactions are enabled on the Visa Check Card or Visa Debit Card
• Provide Cardholders with examples of the types of Cardholder actions that may be
required to initiate a Visa Transaction on such Cards
• At least 30 calendar days prior to implementation, notify Visa U.S.A. that it does not
require that all Non-Visa Debit Transactions be authenticated by a PIN
• Clearly communicate to its Cardholders at the time of implementation of such
processing or at the time of issuance, and on an annual or more frequent basis
thereafter, that the provisions of its Cardholder agreement relating only to Visa
Transactions are inapplicable to non-Visa transactions
6.2.A.7.c An Issuer that enabled Non-Visa Debit Transaction processing prior to July 1, 2008
must comply with the provisions of Section 6.2.A.7.b no later than January 1, 2009.

Here's what we say at my bank to explain your bolded bullet (not legal advice - no claim of "correctness")

(Bank name) currently participates in the (name of networks) (PIN-Debit Networks ). These networks are not Visa networks. When you conduct a PIN-less debit card transaction using the NYCE, PULSE, or Cirrus networks, your liability for unauthorized transactions is limited to either $50.00, or $500.00, depending on when you notify us.

(Bank Name) also participates in the Visa Network. To initiate a Visa transaction, you must select a payment option that sends your transaction over the Visa network. Merchants must provide you with a clear way of choosing to make a Visa Check Card transaction if they support this option. When you conduct a PIN-less debit card transaction using the Visa network (Visa Check Card transaction), you are covered by Visa’s zero-liability policy, but you must still notify us of unauthorized transactions as outlined in your Electronic Funds Transfer disclosure .

We don't mail out the cardholder agreement - we mail an annual disclosure that contains this language to satisfy the requirement.

We have the disclosure in our agreement and we also include it on the back of our statements so we don't do an annual mailing.

Would MasterCard have the same requirements regarding an annual mailing?

Can we use a statement message once a year directing them to the website that has the Annual Disclosure Statement? I am curious if other banks are doing this.