Answer:
Yes, you can. It's a good idea to have a piece of your policy address this question, because customers often try to reopen accounts or regain access that has been denied them.
The "second chance" concept is not officially endorsed by regulators, but remember that regulators are interested in the overall effectiveness of your program at keeping customers within the six/month transfer limits, not in micromanaging your process. If you decide to reopen an account or reinstate privileges or access, do so with the express understanding that you will pull the plug the first time another infraction is made, and that the change will be permanent.
First published on BankersOnline.com 12/07/09
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