ATM/Opening Fees Affect Advertising Acct. as Free?
Answer by John Burnett, BOL Gurus Guru Bio
Question: We are considering advertising an account with no monthly fee with a free debit card. There would be a required opening deposit. The debit card would have ATM fees charged if used at foreign ATM's. Will either one of these fees affect advertising the account as free?
Answer: No. Fees for use of foreign ATMs (see Comment 1030.8(a)-4.vi.) don't affect your ability to use "free" to describe the account in an advertisement, nor would the required opening deposit. Be certain, however, that there's no fee that will be assessed if the balance in the account drops below a threshold level. That would be a maintenance fee, and would make your use of "free" a violation.
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