If the bank wants to adopt the new acct availability exception, is a 30 day change in term notice required for existing customers? The bank doesn't currently place new account holds. If existing customer A opens a new account with new customer B, it will affect deposits made by the existing customer on the new acct.

Mgmt says because they get the Reg CC disclosure before they open the new account, existing customers don't need advance chg in term notice. What do you guys think?

If you are only going to apply it on accounts going forward and you give them a disclosure at account opening with that in it, your existing account holders could care less.