I will simply add here that, although the opt-in need not be in writing, you'll need to have a dependable procedure for documenting that an opt-in was received to keep auditors and examiners at ease. And you need to have a record of when you provided the confirmation of the opt-in, because you aren't allowed to assess an overdraft fee under the opt-in provision until that confirmation has been provided.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8