For prepaid cards we have an issued date and an activation date. It’s not unusual for cardholders to sit on a card for months before activating it. We are trying to come to an agreement on what is a “new account†for Reg. E? Does the clock start at card issuance or on card activation?
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu