I think the original question concerned counter check fees. I don't think it has anything to do with check printing fees, which is given some special treatment (favorable) under the regulation. I think that Analauditor's question has to do with a per use fee for counter checks, and that, I think, is a fee that would trip a CIT notice if increased.
Maybe our "counter checks" are a different type of product than what is being referred to here... but...
Our "counter checks" are checks printed on demand for the specified account. We fee the customer $1 per check that we print for them.
In our case, this most certainly is a "check printing fee" (IMO)... Are you referring to a different type of product than described above?