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#2241077 - 08/14/20 06:07 PM Extending ATM Cut-Off - Redisclose?
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,077
We are extending our ATM cut-off time, which will definitely benefit all consumers. We are updating our Funds Availability Policy when it's effective, but should we also disclose this change via a statement message to our existing customers?

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eBanking / Technology
#2241084 - 08/14/20 07:20 PM Re: Extending ATM Cut-Off - Redisclose? [Re: Mel in WA]
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 5,538
Illinois
Unlike Reg E and Reg DD which only mandate a change in terms notice if the change is to the customer's detriment, Reg CC requires a change any time your funds availability policy changes.

229.18 (e) Changes in policy. A bank shall send a notice to holders of consumer accounts at least 30 days before implementing a change to the bank's availability policy regarding such accounts, except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation.

Using a statement message would satisfy the requirement provided that all existing customer receive it at least 30 days after the change is made.
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#2241086 - 08/14/20 07:29 PM Re: Extending ATM Cut-Off - Redisclose? [Re: Mel in WA]
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,077
Thanks so much, Brian!

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