We are eliminating an annual fee on our credit card. We plan to notify our customers, but do we need to follow the 45-day advance notice provision in Reg Z? I think that 1026.9(c)(2)(v) gives us an out, since it is a reduction in the fee (or elimination thereof).

What say the gurus?

Correct:

(A) When the change involves charges for documentary evidence; a reduction of any component of a finance or other charge (except that on or after October 1, 2022, this provision on when the change involves a reduction of any component of a finance or other charge does not apply to any change in the margin when a LIBOR index is replaced, as permitted by § 1026.55(b)(7)(i) or (ii)); suspension of future credit privileges (except as provided in paragraph (c)(2)(vi) of this section) or termination of an account or plan; when the change results from an agreement involving a court proceeding; when the change is an extension of the grace period; or if the change is applicable only to checks that access a credit card account and the changed terms are disclosed on or with the checks in accordance with paragraph (b)(3) of this section;