I know the rules didn't change on new account holds, but currently our policy states "funds from all other check deposits will be available on the 11th business day after the day of deposit". If we change that to 9th do I have to give 30 days advance notice? The only people it will affect is new customers so I wouldn't think so. Do we have to disclose that change anyway other than on the normal funds availability disclosure given with new accounts?

Hopefully someone will correct me if I'm in error.

You DO have to notify the existing customers; however, because it is not an adverse change (they are actually getting use of their funds sooner than under the old policy) you DON'T have to notify them in advance.

You have 30 days from the date of (positive) change to notify all existing customers.

I'm sure you're right. I just wasn't thinking right about the fact it wouldn't need to be advance notice. I wanted to change it once before but didn't want the hassle of re-disclosing. This might be the time to do it though since we'll be making those other changes. Thanks.

How can you give advance notice to someone who has not been in your bank? If they are already customers then the new account exception will not work for a new account that a current or recent customer opens.

Reg CC considers an account as new for its first 30 days. So an account opened yesterday that received the old disclosure would be entitled to a change notice today, as they would be subject to the new terms.

Advance notice isn't required and technically notice is required within 30 days after the change. At that time the change doesn't apply. Reg CC does say "A bank shall send a notice to holders of consumer accounts at least 30 days before implementing a change to the bank's availability policy regarding such accounts, except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation." Since those accounts won't be affected (they aren't "new" after the 30 days), I could make a case that no notice is required. I suppose technically the 30th day is the hangup, but since it is a favorable change, someone would really have to want to cite you/be on a witch hunt on something questionable like this. Be sure to change it on the disclosures given when you make the change so your practices match your policy.