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Opt-in Notice for Multiple Accounts

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Can one Reg E opt-in notice cover multiple accounts, or does each affected account have to have its own notice? Does the opt-in notice have to list an account number?

A single opt-in disclosure can cover multiple accounts. In my opinion, you should not use a single disclosure, however, unless ownership of the accounts is identical, so you can be assured that all owners at least have the chance of being notified.

As for an opt-in form from the consumer, it, too, can cover multiple accounts, as long as the consumer has the option to make an account-by-account decision to opt in or not. For example, you could list each account potentially covered and direct that the consumer check-mark each to which an opt-in will apply, or ask the consumer to list each account, by number, to which the opt-in will apply. It would not be compliant, however, to include a statement on the form that that opt-in will apply to all the consumer's accounts. The opt-in disclosure does not need to include account numbers at all unless it's also used as a form the consumer can use to opt in.

First published on 6/21/10

First published on 06/21/2010

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