If a debit card is linked to 3 accounts will three letters or opt-in notices have to be sent or can they be combined on one form?

The consumer must be able to make a different decision for each account. You could list all three accounts on a single form, but the consumer would have to be able to make a choice for each account separately.

Ken,
Can we, in the initial disclosure, indicate that the consent will apply to all applicable accounts of that customer unless the customer indicates which accounts will not apply?

I wouldn't advocate messing with the disclosure; the Fed takes a proprietary interest in it, warts and all. You could include that sort of instruction on the form the consumer uses to opt-in. However, the last thing you want to do is confuse the customer. Make things as transparent and simple as possible; you want customers to opt-in without having to ask a lot of questions.

Thanks for your advice John......it is always taken. My thought was that including on all accounts to me would be less confusing for the customer. Some customers (I know as crazy as it might seem) might not even realize some accuounts that will need it.