We are looking at offering a "Free" Checking account. In the planning meeting this morning someone suggested charging an inactivity fee of $5.00/month for accounts that have not had activity for 12 months.

I am just looking for confirmation....
that according to Uniform Unclaimed Property Act (Act 29 of 1995) 567.227 Section 7 (3) A holder may not impose with respect to property described in subsection (1) any charge due to dormancy or inactivity or cease payment of interest unless all of the following are met:
(a) there is an enforceable written contract...
(b) .... value in excess of $2.00, the holder, no more than 3 months before the initial imposition of those charges..., has given written notice...
(c) The holder regularly imposes such charges or ceases payment of interest and does not regularly reverse or otherwise cancel them ...

Especially item (c)... we have never charged this before, however we are considering this on all our deposit accounts. By implementing this on all our accounts... would that satisfy item (c)? (Of course... we'd have to give 30 days advance notice due to Reg DD.)

We are also considering imposing a fee on inactive and dormant accounts. You are correct in your assessment of provision (c). Just be sure that your state has adopted the Uniform act. Although there is a cost associated with having to give notice before assessing the fee (in addition to the Reg DD change notices), we view it as an opportunity to re-establish a relationship.