Answer:
Answer by Randy Carey: What is considered close proximity?
That is totally up to the person making the decision. You might think one month, an examiner might think 10 days. Most Banks just make it a habit to include a Reg. E disclosure with every new debit card issued.
Answer:
Answer by Ken Golliher: Hand one out when the account is opened regardless of whether they sign up for an E service (because they can sign up for one someplace else). Hand one out again every time they sign up for another e-service.
Alternatively, keep track of when it is distributed and debate your reviewer on your timing.
One's a lot easier than the other.
First published on BankersOnline.com 4/8/13
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