We currently only allow our Health Savings Account customers "view only" service within online banking. We now have online banking set up so that the customer can make transfers into their HSA and the system will code it correctly or stop it if they are over their limit. Our current TISA disclosure for the HSA account states online banking is "view only", so we will be updating that. My question is, does this change require 30 days notice? We will provide notice to our customers that this is changing, but it's not going to affect anyone negatively, so do we need to notify them ahead of time or can we simply put the service in place and send an updated disclosure out with our periodic statements?

Thanks!