Advertise Checking Account as "Free"

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Question:

We would like to start charging our customers who want a paper checking account statement as opposed to an electronic one $1 a month. Can we still advertise a "free" checking account product if we do this?

Answer:

I think you'd be skating on awfully thin ice with this. It sounds too much like a monthly maintenance fee to me. Although statement fees are not specifically mentioned in Regulation DD as included in the fees that must be disclosed, a statement is clearly a feature that is integral to a checking account (unlike a fee for ATM transactions, which are usually thought of as "extras." There remains a significant percentage of our population that is not capable of receiving electronic statements, so it would be hard to suggest that the printed statement is an "extra." I think you lose the ability to call a checking account "free" if you charge for statements.

First published on BankersOnline.com 11/07/05