With regards to services that can facilitate an electronic transfer, is there a reasonable time period from account opening and providing the EFT disclosure that a consumer can enroll in these services and not have to have another EFT disclosure provided to them.

For example, consumer opens new account today and signs up for online banking - is given the EFT disclosure. Next week the customer signs up for the bill pay module in the online banking service. Must we provide another EFT disclosure (assuming it had not changed in the interim).

Can we set a reasonable time period such as 7 or 10 days from account opening if the EFT disclosure has not changed?

That sounds pretty reasonable to me. "Reasonable" is not defined in the regulation.

7 to 10 days is certainly "reasonable" but if it was 7 to 10 months, maybe, 7 to 10 years, probably not. The easiest thing is to say if you have to ask, give the disclosure that costs you 2 cents.