If you are reducing a withdrawal limit due to fraud, you could make the argument that the change is to secure the payment network, but you will still have to notify the affected customers within 30 days.
1005.8(a)(2) Prior notice exception. A financial institution need not give prior notice if an immediate change in terms or conditions is necessary to maintain or restore the security of an account or an electronic fund transfer system. If the institution makes such a change permanent and disclosure would not jeopardize the security of the account or system, the institution shall notify the consumer in writing on or with the next regularly scheduled periodic statement or within 30 days of making the change permanent.
I guess my question is, if you are concerned about a customer depositing fraudulent checks, why do they still have a card? See the commentary to this section.
2. Changes not requiring notice. The following changes do not require disclosure:
i. Closing some of an institution's ATMs;
ii. Cancellation of an access device.
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