We will be converting to a new bill pay service (Checkfree) whose payment process differs from our current one in that instead of the payments coming directly out of the customers account when processed, payments will be made by the service on behalf of our customer. The service then debits our customer on the scheduled date via ACH. In the case of a payment not being collected from the customer due to insufficient funds, the amounts owed are to the bill pay service and not the Bank. We are updating our Online Banking Agreement with the new terms of service and will send communications out to ensure our customers accept the new terms and are educated on the new platform and processes.

This will be a change to the bill pay service, but would this change require a change in terms notice? There is no additional fees to the customer so I don't think a change in terms notice (21 days prior) is required.

Am I correct or am I missing something?