Excess Debit Changes-Additional Thoughts
By Amy Kudlacek
After running my blog yesterday, I had a few additional thoughts (I hate it when that happens) 
. First off, both your Truth in Savings Act disclosures and Electronic Funds Transfer disclosure require you to disclose any transaction limitations associated with your accounts. That means if you want to take advantage of the new Regulation D changes, you must update your disclosures. You need to ensure that you "do what you say and say what you do".
I am also anticipating that you will get some calls from vendors wanting to sell you customer notification documents. Under both TISA and EFT, there is no advance notification requirement to make this change. In fact, since the change is in the customer's favor, there is no notification requirement. Basically, you can make the change and not say a word. However, you may want to alert your customers purely for customer service reasons.
Also, don't forget to check with your core processing system. If you have reports generated to help monitor excess debits, they may have to make some changes as well. As mentioned before, this rule goes into effect July 2, 2009, which is not a lot of time.