Reg E OD Opt-In by Phone

We utilize the Reg. E Opt-in Model Consent form which includes a section that addresses "What if I want BANK to authorize and pay overdrafts on my ATM and everyday debit card transaction?" the form states: "If you also want us to authorize and pay overdrafts on ATM and everyday debit card transactions, call xxx-xxx-xxxx, visit www.xxxxx.com, or complete the form below and present it at any of our locations or mail to: xxxxx. "

So my question is, if the customer calls and consents to "opting-in" can we just notate this or should we then send the consent, request for it back, then provide the required confirmation....etc. all before we can actually start charging fees to the customer. What records/paperwork, etc do other banks maintain when a customer' s "opt-in" election/consent is made via phone to the bank? Thanks.

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.

Document and send the confirmation.