Do we need to re-disclose if we are changing the cutoff time?

Cutoff time for transfers conducted through the Online Banking system?

If this is what you are referring to, we have the cutoff times incorporated into our customer agreement and the vendor incorporates our cutoff times in the pop up box that comes up when that prompts the customer to say "Yes I want to make this transfer of $50.00 from my checking to my savings."

Anywhere in your system that informs your customers of cutoff times you need to change. Revise your customer agreement if these times are stated in the contract provisions. Also, if you have a large volume of customers that conduct transfers you could put a banner notice on the homepage to inform the users or you could send out an email notification to all registered Online Banking users. But just for the sake of customer service, I would definitely try to get the message out. Your vendor may have some better advice.