On our internet site, we offer enrollment into billpay. We do not post the actual fees but put a 'check box' under 'Payment Plan' which advises 'Please contact your Financial Institution directly for Billing Information'. Are we required to post on the site itself the actual fees involved or will the 'contact' instruction be sufficient.

If they can enroll online, you must post the fee schedule and any other disclosures. If not, referring customers to the branch for sign up and disclosure is a good plan.

For ease, you should set up the entire enrollment online or offline. That would include the cost of the program. Why would I want to enroll online only to find out later that the cost is too high or that I would have to wait for a certain time and call the bank the next business day to find out the cost, and then go back and enroll?

Remember, part of what you are selling is convenience. Make it convenient from the beginning by putting the initial process offline (good for security) and allow them to test and complete the process online, or put it all online. In the former, you need a solid process that demonstrates you know what you are doing.