We need to know if we HAVE to allow telephone calls as a method of opting-in. We would prefer that our customers come into the branch, go to our website, or respond by mail to opt-in. Do we HAVE to accept opt-in by telephone?

Section 205.17

4. Reasonable opportunity to provide affirmative consent. A financial institution provides a consumer with a reasonable opportunity to provide affirmative consent when, among other things, it provides reasonable methods by which the consumer may affirmatively consent. A financial institution provides such reasonable methods, if –

ii. By telephone. The institution provides a readily-available telephone line that consumers may call to provide affirmative consent.

Thank you!

You don't have to offer every option. The Commentary just tells you what would be reasonable for each method if you choose to allow that method.

The Fed did say in its analysis that accompanied one of the Federal Register documents involved that it believed that banks would feel the need to make opting in as easy as possible, in their own self-interest. Restricting the opt-in channels may be needed, though, in order to manage the process.

Thanks for the clarification!