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.
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.