The Model A-9 disclosure was created a number of years ago and the section titled What fees will I be charged states "if the account is overdrawn $$.$$ or more for 7 consecutive days, we will charge an additional $.$$ each business day after the 7th day." The bank actually uses 7 consecutive calendar days before charging the fee for consecutive days and uses business days thereafter.

My question is in regard to clarifying the disclosure to read "consecutive calendar days" and then "consecutive business days".
Technically, consecutive days is defined as meaning calendar days, and business days are defined in our account agreements. Would we need to redisclose the Reg E Opt-in to consumers in the form of a change in terms?

The whole program will eventually be reviewed and/or overhauled based on future developments, but for now I need to determine if this one change will trigger redisclosure. I thought there was something in the regs about clarifying disclosures, but I am not locating it in my rush for an answer.

Business days are not always consecutive - I see no point.

The CFPB has already specifically labeled sustained overdraft fees as junk fees. I would just bite the bullet now and pull the trigger on them. Charging any fees for an overdraft will soon be a thing of the past.