We have always set our policy to read that our banking centers have various cutoff times not to be earlier than 2:00 p.m. Because of a physical move of our data processing center we are going to be changing some banking centers current cutoff times and banking centers that have no cutoff times, will began cutting off their days sooner. Since we originally disclosed the possibility of a cutoff, do we need to give written disclosure to all customers 30 days prior, or can we just post a notice in the lobbys of the banking centers that will be experiencing the changes, 30 days prior?

We have markets in 5 states and the changes is only effecting one region in one state.

I think you have to give each customer affected a notice of change 30 days in advance. You could use a statement message, a statement stuffer or a direct mail piece if you're short of time, but I would not rely solely on lobby notices.

I agree with Brenda about giving each customer a disclosure. I always feel more comfortable giving a notification whenever we are changing anything that was originally disclosed to the customer. Plus it gives me one for my file. I have not checked, but I would bet that Reg CC is one that would require a notification.

Opinions are mine not my employer