Good morning,

Do we need to send out a notice if we are changing our business day from Monday-Saturday to Monday-Friday for error disputes?

Does it need to be a 30 day notice?

Since this would adversely impact the availability of funds under Regulation CC as funds could be held longer periods of time, yes, 30 days advance notice would be required under 229.18(e).

We actually already have Reg CC on that schedule, We had Reg E listed differently.

The more I am thinking, maybe this would apply for (ii) Increased liability for the consumer


Sec. 1005.8 Change in terms notice; error resolution notice.
(a) Change in terms notice. (1) Prior notice required. A financial institution shall mail or deliver a written notice to the consumer, at least 21 days before the effective date, of any change in a term or condition required to be disclosed under § 1005.7(b) of this part if the change would result in:
(i) Increased fees for the consumer;
(ii) Increased liability for the consumer;
(iii) Fewer types of available electronic fund transfers; or
(iv) Stricter limitations on the frequency or dollar amount of transfers.

Yes. But under Reg E, you can send the notice 21 calendar days in advance of making the change.

Yes, thank I did see that as well.

Since both Reg E and Reg CC require advance notice, in order to comply with both we would send a notice 30 days in advance since sending a notice 21 days in advance under Reg E would violate the Reg CC requirement.

We already run Reg CC on M-F business day, we are only updating Reg E.

Got it. The 21 day advance notice it is.

Got it. Then 21 day advance notice it is.