Answer:
That's arguably the elimination of access to an EFT service deserving of a 21-day notice under Section 205.8(a)(1). I can't imagine your bank wanting to sit still, however, for a three week lead time during which a customer could go wild with a card. So I'd invoke Section 205.8(a)(2), the exception to the notice requirement when immediate action is required to restore the security of the customer's account. You can't escape the notice requirement entirely, IMO, but you won't need to make it an advance notice. Simply inform the customer that the card has been blocked from future activity and advise him or her to contact any merchant who is using the card number for recurring payments to make other arrangements.
First published on BankersOnline.com 7/02/07
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