Reg DD 1030.3(c)
Last edited by Ken_Pegasus; 05/05/15 01:13 PM. Reason: Highlight quote from regulation
Relation to Regulation E (12 CFR Part 1005). Disclosures required by and provided in accordance with the Electronic Fund Transfer Act (15 U.S.C. 1693 et seq.) and its implementing Regulation E (12 CFR Part 1005) that are also required by this part may be substituted for the disclosures required by this part.
In other words, if you are providing required disclosures under Reg E, your obligations under Reg DD are waived so you can choose to go with the 21 day notice. (Note there is nothing wrong with being conservative and going with 30 days advance notice.)
Regulations aside, Do customers have to sign a contract to use this new service? If so, based on 1005.7, this would not be a change in terms. All you would need to do is provide an updated EFT Disclosure including the new transaction type and new fee in close proximity to the customer enrolling in the service, and prior to charging a fee.
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