A bank may not use the word “free” or any similar term to describe an account if it is possible under any circumstances for a maintenance or activity fee to be charged on the account. Monthly service charges and minimum-balance fees are examples of maintenance charges. Fee imposed for exceeding a specified number of transactions and per-check charges are examples of activity charges. Balance inquiry step-payment, dominant account, NSF, check certification, check reorder, and similar charges are neither maintenance nor activity charges. Though a bank may not advertise an account as free because it imposes maintenance charges, the bank may advertise a service as free. Free deposits or free withdrawals are examples.
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My opinions are not to be construed as legal advice.