We have recently converted to a new computer system. Due to the conversion, it has become necessary for our overdraft program to work correctly to place holds on non-PIN based debit card transactions.

First: Do we need to disclose the change to our customers? (I'm quite certain we do)

Second: Does Reg E have requirements for hold notification?

Third: If not Reg E, which Regulation would address holds on debit card transactions. Reg CC doesn't appear to address it.

Thanks in advance for any responses.