Yes, we believe you must provide new Regulation E disclosures every time a customer adds a new electronic fund transfer (EFT) service to an account. Regulation E requires that you provide new disclosures whenever a new electronic fund transfer service is added to a customer’s account, if the terms and conditions are different from those provided in your initial Regulation E disclosures. 12 CFR 1005.7(c). Since you told us that your initial disclosures included a disclosure that customers could make debit card transactions, you should not need to update the terms and conditions for the account when adding the debit card service. See 12 CFR 1005.7(b)(4).

However, the Regulation E Official Staff Commentary states that if you have given the customer early Regulation E disclosures, but the customer later contracts directly with your institution for a new EFT service, you must provide new Regulation E disclosures in “close proximity” to the time when the customer contracts for the new service. Official Interpretations, 12 CFR 1005, Paragraph 7(a), Comment 1. Because you will be adding a new type of EFT service to the account by adding a debit card, we believe the Regulation E requires you to provide new disclosures.