Our Reg E disclosure currently discloses that there are daily and monthly limits on mobile deposit amounts, but does not disclose the specific dollar amounts for those limits citing the exception for confidentiality/security from the commentary on section 1005.7(b)(4). In practice, we appear to have several levels or tiers of limits, almost like credit limits.

Now management wants to reduce some of the limits.

How do we comply with the change in terms requirements, since we do not currently disclose specific dollar amounts, if we lower a customer's daily/monthly limits which would have an adverse effect on that customer?

Sec. 1005.8 Change in terms notice; error resolution notice.
8(a) Change-in-Terms Notice

3. Limitations on transfers. When the initial disclosures omit details about limitations because secrecy is essential to the security of the account or system, a subsequent increase in those limitations need not be disclosed if secrecy is still essential. If, however, an institution had no limits in place when the initial disclosures were given and now wishes to impose limits for the first time, it must disclose at least the fact that limits have been adopted. See also § 1005.7(b)(4) and the related commentary.

I am confused. What does a mobile deposit have to do with Regulation E?