When offering overdraft protection, do we need to disclose to customers that we would report them to the credit bureau if they don't pay? Also, do we need to do that for other loans?

If you are extending credit to a consumer and you may report negative information about it to a consumer reporting agency, section 217 of the FACT Act added a requirement that you provide a notice to that effect. The notice may either be provided before or up to 30 days after furnishing the negative information and only needs to be provided once per account, not every time you send information.

So you can provide the notice up front at account opening or you can do it only when you are actually going to be furnishing negative information. When ever you do it the disclosure has to be "clear and conspicuous".