ATM and debit card fees are not considered maintenance or activity fees that prevent a bank from advertising an account as free (unless use of the card is mandatory to use the account). However, they are fees that have to be disclosed under 230.4 and 230.6, and under Reg. E, 205.9(b). Reg. E allows these fees to be separately disclosed on the statement, or aggregated (even with non-EFT fees). However, I'd say that the industry trend is toward more detail (less combining) on fees when it comes to statement time.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8