We want to add a new checking type to our business checking products.
They want to call it free business checking but they want to charge .25/item over 100 checks and charge $2 month if they want paper statement.

I know TIS doesn't apply to business accounts but do you think we will be criticized by the regulator for calling this free checking?

That would be a UDAAP all the way as it is false advertising. UDAAP is not limited to consumers.