We are in the process of changing person 2 person payment vendors. The issue is our current vendor will suspend operations before our new vendor is in place by a month or two. Does this require a disclosure under Reg E that would need to be 21 days in advance?

Are you saying that a service you offered to your customers is going offline for two months?

Unfortunately, the answer is yes.

Anyone have any thoughts on this?

The only time that disclosure is not required is if changes are being made to "protect the security of a funds transfer system." Changing vendors does not fall into this category so 21 days advance notice would be required since we are reducing the type of available funds transfers. These is no carve out for a short period of time.