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Does a charge for a paper statement cancel out “Free Checking”?

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Question: 
We are revising our deposit accounts and one account will be titled Free Checking. This product will have e-statements as the default at no charge. Since e-statements are the default, we will charge $3.95 for a paper statement. Is this a concern relative to Unfair, Deceptive, or Abusive Acts or Practices?
Answer: 

Yes, it is a concern under UDAAP, as you will be incorrectly labeling the account as “free” when there is a “catch”. You must either remove the word ”free” from the name of the account or remove the charge fro the paper statements.
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First published on 04/03/2016

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