Reg E - Opt In Revoked

When a customer opts-in to include debit card and ATM transactions into overdrafts, we send a confirmation letter that includes information on how to revoke this decision. When they revoke (cancel) the opt-in, are we required to send a confirmation notice? It doesn't seem to be required per the regulation, (1005.17(f)), but I'm thinking it may be a good business practice.

And I agree with you. When it comes to overdrafts and overdraft fees, improved communication and transparency with the customer is a definite plus. I suggest you confirm that the opt-in has been cancelled, remind the customer of the potential for being rejected at an ATM or point of purchase, and explain how to opt back in (subject to approval, of course).

Bringing this up: We don't send a confirmation letter when they opt in. They get a copy of the form (the model form provided by CFPB) they signed when they opt in. If we are using their form and that's what they receives as their confirmation, should we add the 'right to revoke' language in the form?

Thanks.

I think I found my answer - Under 1005.17(d)(6), we can modify the form to include the right to revoke consent language if we uses the form as the confirmation.