Arguably, both Regulation E and Regulation DD call for disclosures concerning such limitations (Regulation DD refers to limits on withdrawals and deposits), and both call for a change in terms or subsequent disclosure if there's a change that is adverse to the consumer. Disclosures that are required by both regulations only have to be made once to comply with both, and a notice of change would similarly only need to be given once.
You can use the Reg E notice period of 21 calendar days and be compliant with both rules, too, in this case.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8