Sending DC to Customer if Current DC not Expired?

Question:

Can a Financial Institution send out a debit card to an existing customer, even if the current card is not expired? The FI would be sending the new card as a marketing tool, so to someone who hasn't used the card in quite some time. What about if it is a credit card? Same question, but is the answer the same?

Answer:

For debit cards, if it's going to replace the existing debit card, provisions in Reg E at 12 CFR 1005(a)(2) give you that authorization. If it is in addition to the existing debit card, provisions in 1005.5(b) and comment #5 in the Official Staff Commentary to that section say you can do so, but such card must be issued as not validated and the institution must follow specific disclosure and validation processes further spelled out in that section.