Could a bank do the following:

All products have fee for paper statements (disclosed in TISA), no fee for e-statements (disclosed in TISA)

No accounts are advertised or use the term free in the product name (avoid UDAP and regulatory violations for advertising)

Customers have to sign up for the e-statements on their own (demonstrate consent for e-sign)

I've read through several of the posts and I think this would be okay (may get some customer push-back because there is no free paper statement option), but I just want to make sure I'm not missing anything?

Thanks

That sounds like you've summed it up pretty accurately.

It is reasonable to charge for paper, and not e-statements.

If you get a lot of push back, you might be able to emphasize the free e-statements, or lower cost accounts, etc. You don't want to hide attributes, but you don't want to mislead either.

Sounds like a good plan. If there's much customer pushback, now's a good time to deflect it. Postage is up and earning opportunities (loan demand and bond yields) are down. It's not fair for customers who prefer low cost e-delivery to pay the same price as those who prefer paper documents.