When we are unable to obtain updates to required information from a customer, we begin restricting the account and eventually close it. Our account agreements give us broad rights to cancel any service on the account, such as checkwriting and bill payment. We would like to send the client a notice that if information is not provided, checking, bill payment and other services will be cancelled in 30 days and we will stop processing bill payments (including recurring scheduled payments) and will stop paying any checks presented after that. I did not find UCC or Reg E provisions addressing the closing of an account, but am trying to determine if we should be concerned about claims by a client for payments we reject. I'd appreciate an thoughts.

I would not close an account without some sort of notice unless is was imperative to avoid immediate loses. You could immediately restrict the account to additional deposits if you choose. If the account is subject to Federal benefit deposits, an appropriate delay in closing must be given. Other than that, the timing is up to the bank. We use to give 10-15 days, but 30 is up to you.

Thank you for your response.