Based on the “applicability” of the rule, I agree that the coverage would apply to overdraft lines of credit est. during active duty.
(a)(1) Applicability. This part applies to consumer credit extended by a creditor to a covered borrower, as those terms are defined in this part. Nothing in this part applies to a credit transaction or account relating to a consumer who is not a covered
borrower at the time he or she becomes obligated on a credit transaction or establishes an account for credit. Nothing in this part applies to a credit transaction or account relating to a consumer (which otherwise would be consumer credit) when the consumer no longer is a covered borrower.
Pages 43579-80 of the final rule have some discussion of overdraft lines of credit: https://www.gpo.gov/fdsys/pkg/FR-2015-07-22/pdf/2015-17480.pdf.