I was told that we have to provide notice now at the ATM screen that the customer is about to generate an overdraft. I cannot find this in 205.17. I recall something similar to this from the old OD rules, but that was if you were advertising ODs. Any thoughts?

It harkens back to the best practices listed in the February 2005 ODP guidance. The Fed has recently said that it feels the best practices are still best practices (unless regulations have superseded them). It probably can only work at your own ATMs, but it's also wise to post a notice at the ATM to the effect that ATM transactions that overdraw an account may result in OD fees.