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#1838646 - 08/01/13 07:37 PM Debit card daily limit decrease
ComplianceNerd Member Joined: Jan 2011 Posts: 58	Will the daily debit card daily withdrawal limit decrease trigger notification requirements just from Reg E point of view or from Reg DD also?
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Deposits and Payments

#1838655 - 08/01/13 07:53 PM Re: Debit card daily limit decrease ComplianceNerd
'Lil Freak! 10K Club Joined: Sep 2005 Posts: 10,596 The psych ward	Reg E: Lowering a cardholder's limit would meet the definition of change in Reg E 1005.8 (a)(iv). (iv) Stricter limitations on the frequency or dollar amount of transfers. Why would Reg DD be involved _________________________ No, I didn't lose my mind. It got scared and ran away.
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#1838660 - 08/01/13 08:00 PM Re: Debit card daily limit decrease ComplianceNerd
John Burnett 10K Club Joined: Oct 2000 Posts: 40,086 Cape Cod	Disclosure of that limit is required under both Regulation DD section 1030.4(b)(5) and Regulation E section 1005.7(b)(4). Disclosure of the reduced limit is required under 1030.5(a)(1) and 1005.8(a)(1)(iv). Regulation DD defers to Regulation E when there's a disclosure required under both. Regulation E calls for 21 days' advance notice of the change, but, under 1005.8(a)(2), gives you an "out" on the advance notice requirement "if an immediate change in terms or conditions is necessary to maintain or restore the security of an account or an electronic fund transfer system." Even in these circumstances, however, if the change is made permanent, you must provide a change in terms notice "in writing on or with the next regularly scheduled periodic statement or within 30 days of making the change permanent." Also, review Regulation E Comment 8(a)-3. _________________________ John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1838665 - 08/01/13 08:06 PM Re: Debit card daily limit decrease ComplianceNerd
Lilly C 100 Club Joined: Dec 2004 Posts: 209 Sunny Florida	John, what if you are temporarily increasing the limit per a customer request? are we required to disclose?
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#1838673 - 08/01/13 08:13 PM Re: Debit card daily limit decrease ComplianceNerd
John Burnett 10K Club Joined: Oct 2000 Posts: 40,086 Cape Cod	No. Consider that the customer already knows what you'd be disclosing to him or her. And, to take it a step further, if the request was in fact temporary, and the agreement was that it would revert to the old limit two weeks later (or on an agreed date), you would not need to make a disclosure of that decrease. You might consider doing it as a courtesy (Mr. Jones, as we agreed, the temporary increase of your daily debit card purchase limit to $5,000 will end next Tuesday. This is just a reminder that it will revert to $1,500 at that time.) Since it's not required, it could even be given by telephone -- just make sure you're talking to Mr. Jones-- don't leave the information in a message. _________________________ John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1838685 - 08/01/13 08:42 PM Re: Debit card daily limit decrease ComplianceNerd
Lilly C 100 Club Joined: Dec 2004 Posts: 209 Sunny Florida	that's very helpful. Thanks, John. Can you tell I'm paranoid about missing disclosures. Ha!
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#1838721 - 08/01/13 09:56 PM Re: Debit card daily limit decrease John Burnett
'Lil Freak! 10K Club Joined: Sep 2005 Posts: 10,596 The psych ward	Originally Posted By: John Burnett Disclosure of that limit is required under both Regulation DD section 1030.4(b)(5) and Regulation E section 1005.7(b)(4). Disclosure of the reduced limit is required under 1030.5(a)(1) and 1005.8(a)(1)(iv). Regulation DD defers to Regulation E when there's a disclosure required under both. Regulation E calls for 21 days' advance notice of the change, but, under 1005.8(a)(2), gives you an "out" on the advance notice requirement "if an immediate change in terms or conditions is necessary to maintain or restore the security of an account or an electronic fund transfer system." Even in these circumstances, however, if the change is made permanent, you must provide a change in terms notice "in writing on or with the next regularly scheduled periodic statement or within 30 days of making the change permanent." Also, review Regulation E Comment 8(a)-3. Thanks John--Once again I learned something new today from BOL! Last edited by 'Lil Freak!; 08/01/13 11:35 PM. Reason: added "once again" because I learn something new every time I'm here! _________________________ No, I didn't lose my mind. It got scared and ran away.
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#1926796 - 05/27/14 07:29 PM Re: Debit card daily limit decrease John Burnett
Twins Fan New Poster Joined: Apr 2013 Posts: 5	If the daily limit increase or decrease was requested by the customer and is to be a permanent change, do we need to disclose the change?
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#1926835 - 05/27/14 08:28 PM Re: Debit card daily limit decrease ComplianceNerd
John Burnett 10K Club Joined: Oct 2000 Posts: 40,086 Cape Cod	No, although it would certainly be a reasonable expectation that you would acknowledge the request and confirm that it had been implemented. _________________________ John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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