Right now we are not doing the Opt In for Reg E. We have never offered access to the OD Limit through the debit card. We are looking at changing this, like many other banks. My question is, say we decide to start this Jan 1, 2011. Will we jsut get new customers the opportunity to Opt In at account opening and have the 45 days to get existing cusomters onboard like the July 1-August 15 deadline for now?

Thanks

No, because none of your customers currently have the service, you will need to treat each of them as a "newbie." The 45 day period was used for the effective date of the rule because there are a lot of banks who had customers already in overdraft service for cards.

If you decide to offer overdraft service for card-accessible accounts beginning 1/1/2011, you'll need to solicit each existing account or advertise the availability and only activate the service for consumers who actually opt in.