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.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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