I don't think your TISA disclosure conflicts with the fee, since the TISA disclosure should only apply if a customer withdraws from an account and requests a check. Even then, it's not a required TISA disclosure item.
I don't think you have significant BSA/AML monitoring concerns, frankly. However, I share you concern that bank policy doesn't permit the practice, yet it's still, er, practiced.
There can be a real problem doing this for payees who are entities.
And your third cup of coffee must have really gotten to you. We took well over 20 copies of your post off the boards.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8