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#2196343 - 10/24/18 06:05 PM REG E Disclosure
banker-12 Offline
Diamond Poster
Joined: May 2007
Posts: 1,240
We amended our REG E initial disclosure to include the number of transactions allowed per day; only the dollar limitations was previously included. Also added that the card will be suspended after number of days of inactivity for their protection.

Do we need to send out a change notice?

Thank You.

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eBanking / Technology
#2196349 - 10/24/18 06:17 PM Re: REG E Disclosure banker-12
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
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 § 1005.7(b) of this part if the change would result in:

(iv) Stricter limitations on the frequency or dollar amount of transfers.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2196384 - 10/24/18 08:21 PM Re: REG E Disclosure banker-12
banker-12 Offline
Diamond Poster
Joined: May 2007
Posts: 1,240
There was no change. It has always been the same limitations; just not disclosed. Still need change notice?

Thank You.

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#2197251 - 11/02/18 08:32 PM Re: REG E Disclosure banker-12
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
My opinion: Yes, you need to send the "change" notice. It's not really a change, as you said, but your consumer customers don't know that because it wasn't previously disclosed.
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David Dickinson
http://www.bankerscompliance.com

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#2204620 - 01/31/19 06:19 PM Re: REG E Disclosure banker-12
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 362
Midwest
Our forms vender has notified us that the model form we are currently using for EFT disclosure is being updated to include prepaid accounts/cards. If we don't offer prepaid cards, do we need to update our EFT disclosure?

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#2204679 - 01/31/19 11:19 PM Re: REG E Disclosure banker-12
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
One hint - forms vendors sell forms - even when you don't need them. smile
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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