I would equate auto enrollment in either of these services (which would result in the creation of a temporary ID and password) as issuing your customer an "unsolicited access" device under Reg E 1005.5(b).
In order to comply with the requirements, you would have to comply with all the disclosure and activation requirements of that section of the regulation. There has not been any guidance issued that would circumvent Reg E requirements for providing disclosures in writing.
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