It's a Reg E disclosure concern, so we look to Reg E. Under 1005.8(a), "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) ... 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.
It would appear you do not need to provide notice under the regulation, but it would be good customer relations to announce the new capability. You will need to update your Reg E new account disclosures, however.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8