I believe I have previously seen or heard discussion around possible UDAAP concerns when the minimum balance required to open an account is lower than the minimum balance required to avoid a fee. Does that sound familiar to anybody else or am I just making things up?

Here, as elsewhere, UDAP or UDAAP has become the boogeyman that is raised in response to every possible misstep. Here's a thread that uses both of your key terms, but does not make the correlation you remember.

It seems I have heard of this issue as well. Does anyone have any information regarding this situation?

I know I saw the same thing somewhere recently and I am also trying to "re-find" the source document. If anyone recalls where this was communicated, would you mind sharing?

Yes, I would certainly like to have any info regarding this issue. We have several accounts that require a low opening deposit amount, but a higher account balance to avoid a fee.

It's still an UDAAP even if properly disclosed on all TIS account-opening disclosures?

I think a regulator might find it to be an unfair practice, even if properly disclosed.

I've been searching and haven't been able to find the source document either. I'll keep my eyes open.

Our account requires minimum deposit of $100, but $600 is the required balance to maintain to avoid fee of $6.00 low balance fee. What if the disclosure states "an opening deposit of less than $600 will automatically incur a $6.00 low balance fee on your first monthly statement" ????

This is just my personal opinion here, but if I saw that on my account-opening paperwork as a customer, I'd be unhappy. It feels unfair to me. But that is just my opinion, and I'm not a regulator.

What if the customer never intends to keep the minimum needed to avoid the fee and finds the monthly maintenance fee acceptable?
Just because there is a minimum amount to avoid a fee it does not mean that it is the bank's responsibility to ensure that the customer (after being informed & disclosed) never incurs a maintenance fee. - My opinion and I'm not a regulator

Unless someone can find something that addresses this by one of the regulators, I have never heard of it being an issue and this is like chasing your own tale without something to back up the claim that it might be a UDAAP issue.

Whether Randy meant "tail" or "tale" his statement is still accurate. In an attempt to euthanize a discussion that will evolve into a "truth" based on repetition alone, I'm going to say there is simply no such issue and there is no need to make one out of whole cloth.

If someone can prove me wrong and supply a source, I would consider it a favor.

What you say is true, there doesn't seem to be a precedent based on recent exam findings, but all it takes these days is one complaint to a regulator and the rest will jump on the bandwagon. It never hurts to consider different aspects of how your products/features/fees are set up and the potential benefits/costs to consumers.

I believe the key is making sure the pitfalls are explained.