Ok - I'm sure I am totally overthinking this but I need help walking through it.

We have updated our Terms & Conditions with the Reg CC changes that go into effect on July 1st. We will be sending a change in terms notice out as an attachment to our statements beginning in May/June to provide 30 days notice. My question is....how do we notify those customers that open an account with us within that 30 day notice? My thought was, we could continue running the notice on our statements through July and into August, since Reg CC does state we can provide notice of a change 30 days after the change. However, that states a change that expedites the availability of funds. Not the amounts made available.

We thought we could just start providing the new T&Cs to accounts opened in June, but then we have two sets of T&Cs in play regarding Reg CC.

Am I overthinking this? Any help is appreciated! Thank you!

My recommendation:

Since this change is to the customer's benefit, notice is required 30 days after the change is effective. If you plan to convert on July 1st, then you could send notice via your statement message between 7/1/25 - 7/30/25 and still be in compliance. For new accounts opened in June, you provide the current notice as they will receive the revisions on their July statement. That eliminates the "two sets of T&C's in play."

You are expediting the availability of funds. More funds are being made available sooner since the thresholds are going up.

Notices made in August would be more than 30 days from the effective date and would be late.

See...I just needed someone to walk me through it! I don't know why I was having such trouble thinking this through.

Thank you so much Brian! This makes perfect sense when you say it!

I appreciate your help!!