My bank is looking at charging a minimal fee for copies of past statements for existing and future loans. What are the disclosure requirements as they affect consumer lending? If the fee is associated with a HELOC, would this need to be included in the periodic rate calculation, and also in the up-front disclosures?

Any fee that could be charged to the customer after consummation has to be part of the original contract.

For closed-end credit, the service giving rise to this fee would be a subsequent occurrence. Since the obligation between the parties does not require the borrower to use this service, the charge would not be disclosable as part of the time-of-consummation disclosures.