To add to what Brian said, the reason it is okay to have your fees on a separate fee disclosure is that 1030.3(a) (and specifically comment 1-ii) permit disclosures to be made "in combination with other disclosures or account terms." As an auditor, I've seen quite a few smaller financial institutions take a similar approach with having fees listed on a separate fee schedule (like a lobby brochure). As long as customers are, in fact, receiving the fee disclosure with the TISA, then you should be fine.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com