Our bank charges a telephone transfer fee. This was a new fee added recently. According to Reg E Section 1005.7(b)(5), we must disclose any fees for EFTs or the right to make transfers. I wasn't sure if the fees described in Reg DD applied to this type of transfer fee. Would we need to disclose this fee 21 days prior to the change?
Answer:
Since Reg DD requires disclosure 30 days in advance, that will cover Reg E requirements.