Our bank has a business analyzed checking product which explains and discloses account analysis and calculations. Recently, I see that an individual in the operations department has been placing several customers into account analysis which of course has been charging them. I understand commercial accounts aren't subject to TISA, but we do give a TISA like disclosure called "specific account details" to our commercial account holders. Obviously the customers recently placed into account analysis never received the proper disclosure initially or subsequently. It seems inappropriate to me that we are charging account analysis fees and never notified the customer. I brought this up to the Ops person and they say since TISA doesn't apply, it doesn't matter. I did review our terms and conditions disclosure which does state that we will give written notice within a reasonable amount of time when changed are made to the account. I say we should refund the fees and send notice- obviously this is not a very popular opinion. Any thoughts?