No, you didn't imagine it. Dig out the 11/17/2009 Federal Register
document (actually, you can find it HERE
) in which the final rule was published, and skip over to the 17th page of the document (page 59049 of the FR), middle column, near the bottom, for a short discussion of "Real-time opt-in.
" The Fed thought it might be of some benefit to a consumer to be able to opt-in at an ATM, for example, but was concerned about how to ensure the consumer got all the info that's supposed to be delivered under the disclosure requirements of §205.17 before opting in. So the Fed backed away from the question, making such opt-ins technically unacceptable unless it can be demonstrated that §205.17 requirements have been complied with.