I'll defer to someone with more intimate knowledge of the reg, but I would say that they are Reg DD disclosable (Fees related to deposits or withdrawals; fees for special services, such as blanace inquireries or verification of deposits). Not sure if the P2P fee would be disclosable, but I'd err on the side of conservatism and disclose it.
I hear and I forget. I see and I remember. I do and I understand.--Confucius