Reg DD

If the bank decides to lower the POS limits on our debit cards does that fall under section 230.4(b)(5), triggering advanced notice under section 230.5? Thanks

Regulation E

Sec. 205.8 Change in terms notice; error resolution notice.

(a) Change in terms notice--(1) Prior notice required. A financial institution shall mail or deliver a written notice to the consumer, at least 21 days before the effective date, of any change in a term or condition required to be disclosed under Sec. 205.7(b) if the change would result in: (i) Increased fees for the consumer;
(ii) Increased liability for the consumer;
(iii) Fewer types of available electronic fund transfers; or
(iv) Stricter limitations on the frequency or dollar amount of transfers

Arguably, both Regulation E and Regulation DD call for disclosures concerning such limitations (Regulation DD refers to limits on withdrawals and deposits), and both call for a change in terms or subsequent disclosure if there's a change that is adverse to the consumer. Disclosures that are required by both regulations only have to be made once to comply with both, and a notice of change would similarly only need to be given once.

You can use the Reg E notice period of 21 calendar days and be compliant with both rules, too, in this case.