When there is debit card fraud, the bank cancels the card, and issues a new card with a new number. Is an initial disclosure required to be given with the new card if no terms have changed?

The customer is not contracting for a new service, simply receiving a replacement access device for an existing service. Reg E disclosures would not be required.

Thanks Brian. What about when a card expires and we issue a new card?

Same answer. It is not a new service.

Thanks Brian.