Our understanding is that this is strictly forbidden under the regulation; you must give members the choice and cannot discriminate based on the choice they make.  Remember that ANR isn’t just for Debit cards.  Changing a member's Negative Balance Limit would affect checks and ACH items as well.  The Reg. E Opt in requirement is only for ATM and one-time debit transactions.  You really cannot tie your overall Courtesy Pay program to this Opt In flag.