Years ago we were written up by an examiner because our new account hold verbiage indicated that the rules "would" apply to new accounts. Since we applied the new account holds on a selective basis, we had to change the "would" to "may".

Brenda,
When you were told that you had to change your policy from "would" to "may", were you required to also send it to existing customers since you did "change their availability policy", or did you only have to change it going forward since it did not apply to existing accounts?
The regulation doesn't seem to allow an exception for a notice in change of policy just because it doesn't affect existing customers.