No, we do not believe that a blanket policy of requiring all customers to use debit card PINs would raise any concerns under the fair lending laws, since it would apply equally to all of your debit card customers.

If your bank does proceed with this contemplated change, we recommend providing at least 21 days advance notice of the change. Regulation E requires the delivery of written notice to consumers at least 21 days before making changes that restrict the “types of available electronic fund transfers” for an account. By limiting your customers to PIN-based transactions, we believe that this practice would trigger the 21-day advance notice requirement. We also recommend checking for disclosure requirements stemming from the Visa or MasterCard rules, if applicable.

For resources related to our guidance, please see:

• Regulation E, 12 CFR 1005.8(a)(1)(iii) (“A financial institution shall mail or deliver a written notice to the consumer, at least 21 days before the effective date, of any change in a term or condition . . . if the change would result in: . . . (iii) Fewer types of available electronic fund transfers; . . .”)