Although not expressly required, there are practical reasons to notify your existing customers about the VAU program and of their right to opt out, and also to include the opt-out right in your new account agreements going forward. For example, some customers may perceive the program as a violation of privacy — or simply may not want to take advantage of the program. We found some examples of other banks’ notices that include a description of the VAU program and the customer’s right to opt out. One example is included in our resources below.

For resources related to our guidance, please see:

• Visa Account Updater For Merchants (“Visa card issuers submit electronic files with updates to Visa when a cardholder’s account information changes. Such updates could result from a product upgrade, a portfolio conversion between Visa issuers or from MasterCard, American Express, or Discover to Visa, card expiration, loss or theft, account closure or other changes.”)

• Visa Account Updater For Merchants (“A few days prior to billing, participating merchants submit account numbers through their acquirers for customers with whom they have a card-on-file or ongoing payment relationship. Alternatively, the acquirer may initiate such inquiries on behalf of the merchant. The acquirer submits the data to VAU, which processes inquiries against its database and responds with updates. . . . VAU responses are forwarded to the requesting merchants, who must then update accounts on file before requesting an authorization. Visa will only respond to specific data elements within an inquiry file from a qualified merchant. Responses include account number updates, expiration date updates, closed-account advices and contact-cardholder advices.”)

• TD Ameritrade Debit Card Agreement (Notifies customers about the Visa Account Updater program and of their right to opt out.)