While one could read into the reg that this would make an account no longer free, I don't see that as it wouldn't be a fee as you described or charged on a regular basis. It is a termination fee.
As to the imaged statements, that is an additional service added to an account like an ATM charge or for bill pay. I agree it too should not disqualify an account from being advertised as free.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell