We are going to increase the daily dollar limits on our atm and check cards. Do we need to disclose this?

No.

Reg. E only requires that you notify customers if you are reducing their access to service or their funds.

It's also not something I would "shout from the rooftops" for security reasons. I'd be happy to tell individual customers who inquired, and I'd make sure my initial disclosures are updated (if you had the old cash limits in there).

In reply to:

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I'd make sure my initial disclosures are updated (if you had the old cash limits in there).

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Does this mean that having the cash limits in there is optional? I always thought we had to have them in there.

§205.7(b)(4) includes this sentence: "Details of the limitations need not be disclosed if confidentiality is essential to maintain the security of the electronic fund transfer system."

I am aware of a bank that says "To protect your account and the security of our EFT system, we have set daily limits on the amount of cash you can withdraw and on your merchant purchases." That bank argues that complies with the rule, says it has never been challenged by regulators on it, but concedes they have never defended it in court. They will allow customers to request a different limit (we have to allow a limit of $50 a day in Massachusetts, if the customer wants it!).

In doing a search to see if anyone has addressed the situation where the bank has several different limitation amounts for ATM and debit cards, I came across this old thread. I'm wondering if any of you use a statement like the one in John's post. We have ATM and debit cards that have different limits (e.g., some ATM cards have a $300 daily limit, some have $500, some $600, etc.). Our current Reg E disclosure states the lowest limit, but obviously that's not the limit for everyone. Do we need separate disclosures for every limit? That would be a nightmare, but I'm wondering how else to disclose it. Any suggestions?

Our disclosures name the dollar amount of the lowest card limit, which is what we give everyone to start off with. We then evaluate on a case-by-case basis when customers request a limit increase and increase to a level we are comfortable with, based on the history of how the customer has managed his/her account. We have never been criticized for this practice by our regulators nor our auditors, and we have never named the higher limits in our disclosures.

That's what we do also for the most part; however, sometimes a customer is given a higher limit at account opening (perhaps due to a prior account relationship, etc.). In that case, the disclosure isn't really accurate for that customer. We've never been criticized but there's always a first time.

Does anyone else have any thoughts on this? I'm wondering if it's better to just use a statement like the one John posted above or if it's ok to just disclose the lowest limit. The problem is that the lowest limit isn't always what our customers are given.

The banks that I work with typically disclose the lowest or standard limit set for their cards. While some people may occassionally have higher limits set for a variety reasons, I have never seen a bank criticized for this practice. There are much bigger fish to fry.

Thanks, Randy, that's what I was hoping. We've always done it that way but I never like to use that reason as mu sole reason. I appreciate your help.