Thread Options
#2132880 - 06/02/17 02:59 PM ATM Daily Limit Decrease
GatorsFan Offline
New Poster
Joined: Feb 2017
Posts: 9
If we want to decrease the daily limit at our ATMs, must we provide advance notice under Reg. E? Our current disclosure states that we may change the limits at anytime without notice sufficient.

Thanks for the input!

Return to Top
eBanking / Technology
#2132887 - 06/02/17 03:13 PM Re: ATM Daily Limit Decrease GatorsFan
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
From Regulation E:

(a) Change in terms notice. (1) Prior notice required. A financial institution shall mail or deliver a written notice to the consumer, at least 21 days before the effective date, of any change in a term or condition required to be disclosed under ยง 1005.7(b) of this part if the change would result in:

(i) Increased fees for the consumer;

(ii) Increased liability for the consumer;

(iii) Fewer types of available electronic fund transfers; or

(iv) Stricter limitations on the frequency or dollar amount of transfers.
_________________________
My Opinions Only

Return to Top
#2133321 - 06/07/17 02:54 PM Re: ATM Daily Limit Decrease GatorsFan
Tabbetha, CRCM Offline
Junior Member
Joined: Feb 2009
Posts: 44
Mississippi
I have a similar issue. We want to increase our debit card limit permanently. I understand in our case that when a permanent change is made a disclosure should be sent within 30 days of the change. Management doesn't feel we do need to send a notice since this is a positive change to the customer. What do you think?

Return to Top
#2133814 - 06/09/17 10:20 PM Re: ATM Daily Limit Decrease GatorsFan
GuitarDude Offline
Power Poster
GuitarDude
Joined: Nov 2004
Posts: 5,924
So Cal
Even though a "loosened" limitation may not require notification, it might be a good idea to disclose. To play devil's advocate, there could be a situation where a customer avoids using his or her debit card or splits a withdrawal into 2 or more withdrawals over several days due to not knowing about the new limit. Disclosing would save the customer those inconveniences.
_________________________
I've just writed a wrong.

Return to Top
#2133951 - 06/12/17 05:26 PM Re: ATM Daily Limit Decrease GatorsFan
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 334
Midwest
It may not be a positive change if their card is compromised and more funds are taken out of their account than what they thought was the limit. I would send the advance notice.

Return to Top
#2133959 - 06/12/17 05:44 PM Re: ATM Daily Limit Decrease GatorsFan
ocbeach Offline
Junior Member
Joined: Sep 2015
Posts: 47
Maryland
Played the same scenario as GuitarDude just last week. Why increase the limits and not notify customers?

Return to Top
#2134326 - 06/14/17 04:52 PM Re: ATM Daily Limit Decrease GatorsFan
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,455
On the Net
I used to speculate as Susielou has, but I believe that is stretching what is considered detrimental to a consumer and wouldn't hold up the change if the bank felt it a positive. I certainly would notify the customers of the increase, but not necessarily in advance.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#2134633 - 06/16/17 02:45 PM Re: ATM Daily Limit Decrease GatorsFan
hobot Offline
Gold Star
hobot
Joined: Dec 2002
Posts: 437
I agree with Susie -- cardholders can be held liable for amounts more than an authorized amount. But it seems unfair if they don't know a higher amount may be applicable. I.e. -- my daily dollar limit is $500. I let my grandson use the card to draw out 200 knowing he could get 500. But I didn't receive the notice yet and it is now actually 800. I would complain about the additional 300.

Also, this issue has arisen with the use of teller assisted ATMs. Apparently if the office is open, even if a teller isn't standing next to the customer, the customer's daily limit isn't applicable? I think these pseudo ATMs are still confusing people (I've never used one). It just makes sense to inform people in advance; especially since regulators seem to care less and less what the bank thinks is good for customers versus what the customers think.

Return to Top

Moderator:  Andy_Z