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#1406205 - 06/21/10 06:22 PM Reg DD
GorgeS Offline
100 Club
Joined: Apr 2004
Posts: 203
If the bank decides to lower the POS limits on our debit cards does that fall under section 230.4(b)(5), triggering advanced notice under section 230.5? Thanks

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Operations Compliance
#1406217 - 06/21/10 06:45 PM Re: Reg DD GorgeS
Dani York, CRCM Offline
Power Poster
Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
Regulation E

Sec. 205.8 Change in terms notice; error resolution notice.

(a) Change in terms notice--(1) Prior notice required. A financial institution shall mail or deliver a written notice to the consumer, at least 21 days before the effective date, of any change in a term or condition required to be disclosed under Sec. 205.7(b) if the change would result in: (i) Increased fees for the consumer;
(ii) Increased liability for the consumer;
(iii) Fewer types of available electronic fund transfers; or
(iv) Stricter limitations on the frequency or dollar amount of transfers
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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#1407347 - 06/23/10 08:13 PM Re: Reg DD Dani York, CRCM
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,870
Cape Cod
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.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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