As I read the reg. the opt in notice is for one time debit and atm usage. Our bank is only sending the notice to existing customers with a debit card and who have our courtesy overdraft program.
We will give customers who open a new account with a debit card the opt in notice at account opening starting July 1 10.

Am I missing something, I feel this is too simple.

Let me know what your institution is doing.

The only other situtation to take into account would be to ensure your staff gives an opt in notice to any existing customers who apply for an ATM/Debit card for the first time.

We have yet to make a final decision, but are discussing sending the opt-in form to EVERY consumer.
Reasons why:
1) opt-in is at the account level, so this allows us to send one per customer instead of one per account without the need to target only debit/ATM card consumers. This may overall save on postage/marketing (maybe, maybe not, depending on how your FI breaks down on card holders).
2) it gives us a chance to market a new service to non-card holders. My guess is that this is the primary reason we're leaning toward this option... revenue replacement!
3) if said customer later decides to get a debit/ATM card, we MAY already have their opt-in preference.