We are trying to clean up our debit card portfolio. We have several customers that have been issued debit cards, but have never used them. If we want to close these debit cards, is there any provision in Regulation E or otherwise that we have to notify them?

Yes. You are required to provide 21 days advance notice according to Reg E 1005.8(a)(iii).

(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 § 1005.7(b) of this part 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.

Just a thought -- if your debit card agreement or the debit card part of your Reg E disclosures had included a statement that cards won't be reissued if they're not used before their expiration dates, you'd be able to drop cards at expiration date without notice if they had not been used.

Of course if you set up LOOOONG expiration dates to cut down on reissue expenses, that isn't going to be much help.

The commentary to 1005.8a specifically states that the cancellation of an access device does not require any notice.