Answer:
If you are referring to the opt-in notice and disclosure required by Regulation E's section 205.17(b)(1), you can deliver it in any way that gets it to your customers, as long as it is in written form (electronic, if your customer agreed to electronic delivery) and otherwise conforms to the format, content and segregated disclosure requirements of the regulation.
Because the disclosure is only required if your bank wishes to obtain a consumer's opt-in to your overdraft service covering ATM and one-time debit card transactions, you do not have to provide it to consumers who do not have an ATM or debit card issued for their accounts. You will have to include the disclosure and obtain an opt-in if one of your current card-free customers later requests an ATM or debit card.
First published on BankersOnline.com 6/07/10
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