(a) Change in terms. (1) Advance notice required. A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under Sec. 1030.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer.
I'm relying on my interpretation of .5(a)(1) to say that a refund is not a required disclosure under 1030.4(b), even though like I said, it may appear on your TISA disclosure. The conservative approach would be to send something out 30 days, but I don't think it's required. Again, deposit contract probably have some blanket language (for example, ours says 30 days for any adverse changes). And from a customer service perspective, earlier notice is probably best.