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#269013 - 10/29/04 10:07 PM Reg E Redisclosure
Compliance Maniac Offline
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Joined: Jan 2004
Posts: 42
I just read a prior post regarding redisclosure of Reg E terms when changed, of which I disagree. And since I am in this situation, I wanted some further input.

Though the reg itself does not address this, the commentary does. The commentary states that if a FI changes the telephone number or address used for reporting possible unauthorized transfers, a change in terms notice is required.

We are in the midst of a merger, hence the address referenced above will be changing and we are contemplating this mass change to all customers. Does anyone agree or disagree?

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Operations Compliance
#269014 - 10/31/04 06:59 PM Re: Reg E Redisclosure
Andy_Z Offline
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If you will discontinue the address and telephone number I would say it is a definite change requiring notice.

If there is an unauthorized transaction, the consumer needs to know who and where to contact. I would say that the OSC @ 205.8, 4 is explicit and the merger would not exempt the intent of this notification. The only time it wouldn't be needed is if you are not holding them to any liability. That isn't generally the case.
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