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#2220177 - 08/21/19 08:12 PM Reg E - Change in Terms - ATM Limit increase
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,664
SmallTown, USA
Is a change in terms required for an ATM Limit increase?

Reg E 1005.7b (4) Types of transfers; limitations. The type of electronic fund transfers that the consumer may make and any limitations on the frequency and dollar amount of transfers. Details of the limitations need not be disclosed if confidentiality is essential to maintain the security of the electronic fund transfer system.

Sec. 1005.8 Change in terms notice; error resolution notice.
(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 ยง 1005.7(b) of this part if the change would result in:

(i) Increased fees for the consumer;

(ii) Increased liability for the consumer;

(iii) Fewer types of available electronic fund transfers; or

(iv) Stricter limitations on the frequency or dollar amount of transfers.
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eBanking / Technology
#2220188 - 08/21/19 09:05 PM Re: Reg E - Change in Terms - ATM Limit increase [Re: OnTheEdge]
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 5,358
Illinois
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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#2220245 - 08/22/19 05:03 PM Re: Reg E - Change in Terms - ATM Limit increase [Re: BrianC]
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,664
SmallTown, USA
Thanks Brian
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