I've looked at the Reg E disclosure requirments and content and I don't see OD program disclosures listed. Are they not a required disclosure at account opening?

If you have an overdraft program requiring a customer opt-in, the disclosure requirements can be found in Reg E 1005.17

We do not offer opt in for one time atm or debit card transactions. Same rules apply?

If you don't have an ODP program, what are they opting into?

FIL-81-2010:
"Give consumers the opportunity to affirmatively choose the overdraft payment product that overall best meets their needs"

We offer an automated overdraft service with a few of our checking accounts. Although the service is automatically available to them; we require them to accept or decline the overdraft service at account opening. Examiners were happy with our approach. Remember, 2010 guidance applies specifically to automated overdraft programs "opting in" to the program needs to be addressed if you offer an automated program.

Thank you for providing the FIL, this will be very helpful.