It recently came to my attention that we (the bank) failed to send a notice to all deposit our customers notifying them of the Reg CC changes last July. The lobby notices were all updated at that time just not a notice mailed to each customer. What do we do now?

I'm sorry I don't have an on-point answer but I just want to mention how painful these situations are for compliance officers. The regulations tell us what to do and when to do it. But in compliance you often get questions like this: "We failed to do it and it was a really, really long time ago too. Now what? You're compliance, so you get to fix it, right?" It's a little like someone having all the instructions for skydiving and copious amounts of time and opportunity to properly prepare, but after your team makes the jump, and as you are all plummeting downwards, someone pipes up with a comment: "I failed to put parachutes in our packs. Your packs have nothing but pots and pans. Oopsie."

These situations are infuriating, challenging, and require some creative thinking about how to address it (usually, numerous steps will be needed, and even then it might not be enough to satisfy your regulators). There is often a lack of clear guidance in the regulations on how to remedy such failures. I hope you get some good answers on here because all I can think of to do is to brace for impact.

This happened at a previous employer when the next day availability increased to $200. We were required to notify the customers, even though it was late. It was put on a statement message.

Just my experience.

You can't go back in time. So you put on your compliance management hat and:
1) correct the problem by sending the notice
2) determine as best you can if any customers were harmed were harmed due to the failure, were there any complaints, and document this
3) was the bank following the correct updated policy, denote that as well
3) determine how/why the notices were not sent, how you discovered the problem, and
4) document what steps the bank has taken to prevent another change management issue from happening.

The best you can do now is turn lemons into lemonade by demonstrating that you have both an effective compliance and change management program so all your examiners could say is "well done." The potential for a violation is not correctible, so make the most of what you have.

Add to Andy's bullet list -- Put a reminder in your electronic calendar to watch for the next set of inflation adjustments in the middle of 2024, to be effective 7/1/2025, and a note that notices must be provided to customers even though the changes will favor the customer.