I am resurrecting this post, as I have an add on question that is similar to the OP. If we are reissuing a members debit card in place of a card near expiration, do we need to mail a Reg E Notice as well? What about lost or stolen cards, or damaged cards; do we need to provide the notice when we replace those also? The language speaks about providing the notice when there is a new SERVICE requested, but not about ACCESS DEVICES. For reference, the close proximity clause would not apply in these scenarios.
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Robert R.
Fraud Specialist
Beaumont, TX