So the customer is given, at the time of account opening, a copy (they can keep) of the completed opt-in notice along with the statement informing them of their right to revoke the opt-in at any time?
If so, it appears you may be in compliance according to comment 7 to 1005.17(b) which says this:
"A financial institution may comply with the requirement in § 1005.17(b)(1)(iv) to provide confirmation of the consumer's affirmative consent by mailing or delivering to the consumer a copy of the consumer's completed opt-in notice, or by mailing or delivering a letter or notice to the consumer acknowledging that the consumer has elected to opt into the institution's service. The confirmation, which must be provided in writing, or electronically if the consumer agrees, must include a statement informing the consumer of the right to revoke the opt-in at any time."
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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