We have a deposit product that includes an add-on service of BillPay. During a product evaluation, it was determined to discontinue the service. Any thoughts as to whether this triggers a Reg E Change in Terms Notice?

The product has its own separate enrollment and terms of service. It is completely optional.

Is it listed on your current Reg E disclosure as a service that is available?

It is not.

Then you don't have a change in terms notice requirement. You undoubtedly plan to provide customers some notice, however. I'd make sure it allows any customer using the service enough lead time to transition.

Yes, we are giving advance notice. We have the luxury of knowing when payments are scheduled, so we can key off that furthest date in our message.

Thanks!