Just a refresher question. Must we offer the Opt-In option to all customers with a debit card? Or can we require an account is good standing for say 6 months before we offer this service?

You never "must" offer an opt-in.

And you can only offer an Opt-in if you provide an overdraft protection service. Without that you have a UDAAP issue.

Just to be clear, we do provide overdraft protection. We are NOT required to make the Opt-In offer to every debit card holder.

No, you are not and you can only provide it to those who have the overdraft protection product.

Just to emphasize the point that you can't offer an opt-in if you don't offer overdraft protection (or courtesy overdraft, if you prefer). To make the opt-in valid and avoid potential UDAAP problems, your overdraft protection, if a cardholder opts in, must allow him or her to use the card to overdraw the account. You could limit that ability to ATM withdrawals (and not provide it for one-time debit card transactions) or vice versa, if you have the system capabilities, as long as you accurately describe what the service allows. But you can't solicit an opt-in if you won't approve any transaction pre-authorization request that would overdraw the account, just so you can impose an overdraft fee if a transaction sneaks through to create an overdraft.