There have been arguments both ways. On the one hand, we are making more relaxed limitation on the dollar amount of transfers on 1005.8(a)(1)(iv); however, there is the potential of the customer having increased liability on 1005.8(a)(1)(ii) since a fraudster could withdraw more funds from the account each day. For these reason I am in the camp of providing 21 days advance notice of the increase if we are doing so without a specific request from a customer for a limit increase.
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