Not by regulation, but they need to understand that nothing that is now required by regulation was always required by regulation.
We are blessed with Reg CC because banks unreasonably delayed availability to the point that congress "fixed" it. Congressional representatives do not dream this stuff up, but react to constituents.
We are blessed with Reg DD because banks hit consumers with hidden fees and were not up-front about such things as interest computation methods and what fees were for.
I think there are another dozen or so regulations that followed this pattern.
So, my response to the Dep Ops folk would be "not yet. But this is the kind of thinking that gets us regulations."
Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.