In reading Reg. E it defines an account as a demand deposit or savings account.

Section 1005.17 states in part, term overdraft services means a service under which a FI assesses a fee or charge on a consumer's account.

That being said, our savings accounts can have a visa debit card. So the potential for overdrawing the account is slim, but it is possible. Can we offer the opt-in requirement like we do with our checking accounts for ATM and 1x debit card transactions and charge the savings account?

Yes. I suggest you see how many fees this would have generated in the last 6 months before you invest the time and expenses involved.

Can we offer the opt-in requirement like we do with our checking accounts for ATM and 1x debit card transactions and charge the savings account?

Ken, unless they offer some sort of ODP program on their savings account (which I cannot imagine) would not the answer be no they can't do that??

They would only be opting into the fee without the benefit of ODP.

Agreed, they cannot opt-in just for the fees; in this regard a savings account is no different than a transaction account. I doubt the value of the effort.