Posted By: ahou
Initial Disclosure replacement card - 03/02/18 05:49 PM
When there is debit card fraud, the bank cancels the card, and issues a new card with a new number. Is an initial disclosure required to be given with the new card if no terms have changed?
Posted By: BrianC
Re: Initial Disclosure replacement card - 03/02/18 06:13 PM
The customer is not contracting for a new service, simply receiving a replacement access device for an existing service. Reg E disclosures would not be required.
Posted By: ahou
Re: Initial Disclosure replacement card - 03/02/18 06:18 PM
Thanks Brian. What about when a card expires and we issue a new card?
Posted By: BrianC
Re: Initial Disclosure replacement card - 03/02/18 07:22 PM
Same answer. It is not a new service.