I believe that you will need to provide an update to your EFT disclosure for the new service (and change the new account disclosure accordingly). This would not be to disclose the fee, rather the new EFT service. This could be accomplished via a statement message, marketing insert or other format to make it more of a new product announcement versus dry legalise. I would agree that this should be added to your Schedule of Fees.
Reg E - 205.7 (c) Addition of electronic fund transfer services. If an electronic fund transfer service is added to a consumer's account and is subject to terms and conditions different from those described in the initial disclosures, disclosures for the new service are required.
Reg E - 205.3 (b) Electronic fund transfer—(1) Definition. The term electronic fund transfer means any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer's account.
The opinions expressed are mine and do not necessarily reflect those of my employer.