The bank is adding the ability to do person to person transfers. There will be a fee of $3. For existing cust who have bill pay,they will have access to the P to P service without having to do anything but register with a 3rd party, once they are in bill pay. My issue is the fee pd to the bank. We need to disclose this new fee.

Will this fall under chg in term notice requirements? Since this is thru our online banking, we can't deliver an updated Reg E disclosure in the bill pay section. In our agreement for online banking, all of these cust agreed (electronically & in compliance with ESIGN) to rec other electronic disclosures about the acct. Could we send them a notice by email?

You could send it through the accepted method in your e-sign agreement.