Our Reg E EFTA new account disclosure states the standard limits for ATM and POS transactions per day. Is it permissible for a bank to set a lower limit for cards to minors? If yes, would we need to state those lower limits in the EFTA new account disclosure? Would we need to provide 21 day advance notice to current minor ATM/POS card holders?
From Reg E Expert Terri Sands: Yes. You can set a lower limit for minors and just like the limits you have in place today, you do not need to state those in your account disclosures. Since you don’t provide limits in your account disclosures, you would not need to address limits in an advance notice.