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Are banks required to provide full Regulation E disclosures when they re-issue a debit card to customers who have lost their card?

No. Section 1005.7 of Regulation E requires that the bank provide disclosures “at the time a consumer contracts for an electronic fund transfer service or before the first electronic fund transfer is made…” Comment 1 to §1005.7(a) of Regulation E further explains that disclosures must be given in close proximity to the event requiring disclosure, such as when the consumer contracts for a new service. In this case, the bank is not providing a new electronic fund transfer service but simply replacing a lost card. (October 2020)

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