We generally use the statement stuffer method because it is more cost effective. If any of the fees are covered by Reg DD, you would allow 30 days after the last day of statement delivery to ensure all consumers have been given a 30-day notice. While ATM fees are not covered, advance notice is generally appropriate. You should look to your ATM and/or customer account agreement to determine what timeframe for changes has been provided to your customers.
Procedures to provide to customers receiving electronic statements should be spelled out in your E-statement agreement.
Thanks for the response!
If I'm interpreting your response correctly, the increase in charge for a lost ATM/debit card would not
require
the 30 day notice under Reg DD?
Aside from the ATM/debit card replacement and the foreign currency exchange mentioned above, the other proposed changes / additions are as follows:
BizPay (addition)
Closing Account (if open less than 90 days) (change which increases the fee)
Remote Deposit Capture (addition)
Night Depository Key Replacement (change which increases the fee)
Positive Pay (addition)
Stop Payments (change which increases the fee)
E-Corp Stop Payments (addition)
Ougoing Wires (change which increases the fee)
E-Corp Stop Payments (addition)
Daily Overdraft fee after 3 days overdrawn (at $3.00 per day)
Do any of the items on the list above run afoul of Reg DD, thus obliging us to give 30 days notice of the change?
Thanks again for your help!