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#2273109 - 07/20/22 04:01 PM Reg E Notice
Anonymous Offline
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Posts: 181
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?

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General Discussion
#2273120 - 07/20/22 04:58 PM Re: Reg E Notice Anonymous
BrianC Online
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BrianC
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Illinois
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).
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#2273128 - 07/20/22 05:46 PM Re: Reg E Notice BrianC
Anonymous Offline
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Posts: 181
We actually already have Reg CC on that schedule, We had Reg E listed differently.

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#2273133 - 07/20/22 06:36 PM Re: Reg E Notice Anonymous
Anonymous Offline
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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 ยง 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.

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#2273141 - 07/20/22 07:06 PM Re: Reg E Notice Anonymous
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted by Anonymous
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?

Yes. But under Reg E, you can send the notice 21 calendar days in advance of making the change.
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BankersOnline.com
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#2273146 - 07/20/22 07:27 PM Re: Reg E Notice Anonymous
Anonymous Offline
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Posts: 181
Yes, thank I did see that as well.

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#2273156 - 07/20/22 07:59 PM Re: Reg E Notice Anonymous
BrianC Online
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BrianC
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Posts: 6,310
Illinois
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.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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#2273158 - 07/20/22 08:02 PM Re: Reg E Notice Anonymous
Anonymous Offline
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Joined: Jun 2021
Posts: 181
We already run Reg CC on M-F business day, we are only updating Reg E.

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#2273160 - 07/20/22 08:25 PM Re: Reg E Notice Anonymous
BrianC Online
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BrianC
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Illinois
Got it. The 21 day advance notice it is.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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#2273161 - 07/20/22 08:25 PM Re: Reg E Notice Anonymous
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,310
Illinois
Got it. Then 21 day advance notice it is.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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