Hello!

Question, does a change in bill pay vendor necessitate a change in terms notice?

No new fees will be introduced, however fees (previously disclosed) may be enforced.

Unable to find anything that speaks directly to this.

The last time this happened for me the new vendor's sales team said no change in terms was needed, everyone was like "phew." Internally we created a chart to show all of the changes (limitations, amounts, etc.) and most required 21 advance notice under Reg E (1005.8). I'd do a thorough review of ALL changes between the old and the new vendor to determine the real effect.

If everything is the same, and you are only imposing fees you previously disclosed, you could have some UDAAP concerns. Look back at articles from CFPB when banks paused certain fees during COVID, and then turned back on without notice.

To clarify further, when I said limitations, I mean ALL limitations. If the frequency amount is changing from 10 per day to 5 per day, the amount of the transfer min/max is changing, the daily transfer limit, and so on, review it all. If this vendor also does non-EFT type of transfers, you may have other areas to review.

Yes, and play close attention to your on-line bill payment agreement. Different vendors do not mean there actually are no change of terms within your legal agreement which might fall outside of any Regulation E concerns.