No, there is no TISA issue. However, you'll need to be able to distinguish between "old" and "new" accounts when applying your service charge routine, and don't make the mistake of handing an "old" customer a disclosure for your "new" account if he asks for information on the "old" account.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8