From a security aspect, the bank sent a replacement card and that card was not activated. In my mind there should be disclosures stating when the current card will be frozen or closed and only the new card would be accepted. If the customer is not looking at these new cards and the terms of the replacement or ignoring them, I can't see why the bank would continue to allow the cards to remain open. The customer may well believe that by not accepting the new card, the line will be closed to use. Due to nonactivation it only makes sense to freeze or cancel the account, or combine these and separately offer to freeze the account until activated, and if this is not done by a predetermined date, it will be closed. Give your customers the option. I'm not sure one choice has to be made, only that the bank needs to communicate the options with the customer and execute their choice, or by default secure the credit by terminating it due to non-response.
Reg Z- VISA Open Loop Card "Replacement"
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Question:
The bank has used "replacement" to replace a private label card with a VISA open loop card. Some of the cardholders have not activated their cards, some probably because they threw away the envelope without opening their mail. The bank is considering placing a block on the cards, pending activation from the customer so that the customer can still activate rather
than reapply. The other option is to send a letter to activate the account within a stated time, otherwise the account will be closed. The consumer would need to apply again for a card. IMO, the second choice is a better customer experience in the absence of some foundational regulation to assert one position or the other.
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