I am reworking our existing ATM/Debit Card disclosure and believe that under Reg E we should have information regarding the fees we charge for ATM and Debit Card issues (w/d, card replacemnent, foreign transactions, etc. We already indicate that we have a surcharge for use of our machine by non-customers.
However, if we do not charge our customers any fees except for foreign transactions and we add this charge under our Curency Conversion section, do we need a statement under "Fees" that there are no charges other than for foreign transactions and other than those listed in our Service Charges and Fees Disclsoure. Currently we do not have a "Fees" section in our disclosure.