Marsha -
This change was made to Reg E back in the spring of 2001, I believe. Search the message threads for "Electronic Check" and you will find a number of different discussions we've had.
In regards to your disclosure question: Our EFT disclosure has been updated so all new customers are OK. We sent out a one-time "update" to our existing customers when the change to Reg E was made. We found that to be our most economical option.
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Pam
The comments above are my own thoughts an opinions, not those of my employer.