No. Yes. No. But it's not viable. Same-county Giant Bank will still cost anywhere from $55 to $300 to file a small claims action if in my state (FL). Add $40 to pay the sheriff to serve the statement of claim. Who's going to foot the initial $1.8M to file the 150K claims and how's the new type of law firm going to get paid?

If you want to have a small government without an effective consumer protection agency then you'll need to ditch mandatory arbitration and permit the class actions to flow.