Historically we have sent a Non-Visa Debit Card Transactions disclosure annually to our customers.
The disclosure begins, "We allow non-Visa debit transaction processing. This means you may use your Visa debit card on a PIN-Debit Network without using a PIN. (Visa Rules generally define “PIN Debit Network†as a non-Visa debit network that typically authenticates transactions by use of a personal identification number, or “PIN,†but that is not generally known for having a card program.)"
Are we still required to send this each year? If so, where, specifically, would I find a description of this requirement? We are an OCC-regulated bank. Thank you.