Dg - I have seen it required based on the commentary to TISA below,
1030.3—General Disclosure Requirements
2. Consistent terminology. Institutions must use consistent terminology to describe terms or features required to be disclosed. For example, if an institution describes a monthly fee (regardless of account activity) as a “monthly service fee†in account-opening disclosures, the periodic statement and change-in-term notices must use the same terminology so that consumers can readily identify the fee.
_________________________
Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.