Answer:
Assuming your account contract documents (including your account agreement and your Reg E disclosures) don't prohibit this, I don't know why you couldn't. Ideally, your contract documents would specifically address this and stipulate that this can happen and the amount of notice required. If they are silent on this issue, I think you could do it but I would recommend providing reasonable notice to the customer with an opportunity for them to avoid the cancellation.
From a marketing perspective, you could use this as a point of contact to probe deeper into what your customer's financial needs are and can lead to providing more suitable products and services. Tie it to security concerns. I can see a conversation starting like this, which could then lead into a discussion about the customer's financial needs:
"In an effort to protect your accounts from unauthorized electronic activity, we monitor our customers' debit card usage over time. We've noticed you have not used your debit card in some time. Is there some reason that you don't find it convenient or efficient to use this card for purchases you are making?"
First published on BankersOnline.com 5/19/08
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