Written confirmation. A financial institution may comply with the requirement in § 205.17(b)(1)(iv) by providing to the consumer a copy of the consumer’s completed opt-in form or by sending a letter or notice to the consumer acknowledging that the consumer has elected to opt into the institution’s service. The written confirmation notice must include a statement informing the consumer of his or her right to revoke the opt-in at any time. To the extent the institution complies with the written confirmation requirement by providing a copy of the completed opt-in form, the institution may include the statement about revocation on the initial opt-in notice.

Ok, after we send the opt-in notices and then if we get one back from the customer opting in, then do we have to mail a copy of the notice back to them confirming their intention to opt-in? do we have to wait for them to reply to this second mailing before we can charge the fees? help! And what about the right to revoke, can we put that in the second letter.

You send the opt-in disclosure. They opt-in. You must send the confirmation notice. Once you send the confirmation notice, you can start charging fees.

The confirmation may be a copy of the customer's opt-in, if it includes a statement advising the customer of the right to revoke the customer's consent at any time (and how to do that). It could also be a separate form or letter if it describes what the customer has done (opted into the overdraft service for ATM and one-time debit card transactions) and advise of the revocation right.

You do not need the customer's acknowledgment of receipt of the confirmation. The tennis ball will have already crossed the net enough times. You can assess an overdraft fee for a covered transaction anytime after you've sent the confirmation, whether or not it actually reaches the customer.

Thanks & has anyone done any employee training on this? Would love to have some suggestions or material.