Change in a check protect line of credit

Posted By: Compliance Chick

Change in a check protect line of credit - 06/05/10 10:57 PM

If I want to increase the annual fee for a Check Protection Line of Credit (open-end non-home secured loan) for current customers, do they actually have the right to opt out of this change?
Am I correct when I catagorize the annual fee as a significnat change in account terms?

I also want to make it mandatory that the check protect LOC is paid by auto debiting the deposit account it protects. When I read section 226.9(c)(2)(ii) this mandatory payment method would not be considered a sigificant change in account terms and they would not be able to opt out of that.