[kmeade]

Per Reg E 1005.8(a)(1), if we increase the daily limit on our Visa debit cards, would this require a 21-day prior notice or a notice within 30 days after the increase? The commentary, 1005.8(a)(3) mentions when the limitation details are omitted from the initial disclosures, a subsequent increase need not be disclosed. However, our initial disclosures did list the limitation details.

Topic

[afaust]

You will need to comply with your current disclosures as they have provided greater protection than the rules require. I also recommend that you review your agreements annually to ensure the intent of your action is accurate based on the regulatory requirements.

Response provided by: Terri Sands.

[Author]

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