We offer direct access to QuickBooks through our online banking product. Would a temporary change in how the customer can access this product constitute a regulatory event and thus an official change in terms notice? We are going through some changes to our online platform and there will be a short period where they would have to access the program by a different method.

No question that the customers should be notified and assisted in this temporary fix, and informed as soon as possible to ensure they are not caught off guard, but would it be considered a change in terms as far as Regulation E is concerned?

Would Quicken be considered an access device?

If this change is not reducing the number or type of transfers available to the consumer or increasing fees, then the change in terms requirements do not apply.

See the commentary to 1005.8.

2. Changes not requiring notice. The following changes do not require disclosure:

i. Closing some of an institution's ATMs;
ii. Cancellation of an access device.

Thank you BrianC !