Are banks required to notify customers of a change to policy that is beneficial to them?

We want to begin to treat ATM checks as we do mobile deposits. This would remove the float and the items would be made available the next business day. With this change, will it require us to have to re-disclose anything to our customers based upon our current funds availability policy? …..“Funds from any deposits, whether in cash or check, made at an ATM owned or operated by us will generally be available on the second business day after the banking day of your deposit.”

Reg CC is one of the quirky regs in that is requires that consumers be notified 30 days prior to an adverse change and within 30 days following a beneficial change. Yes a notice is required.

Examiners got a lot of banks on this when the next day requirements for case by case holds increased from $100 to $200. Since it was beneficial, many banks forgot to send a change in terms notice.