We offer a Gift Card (which is not reloadable) and a reloadable Travel Card. Both cards are "issued" by anothe Bank (they are not branded to us). They both come with a Cardholder Agreement which has load and reload (for Travel Cards) amounts and Fee Schedules.

I was given a memo sent to all our Branch Managers with a fee schedule (which is different than the ones in the Cardholder Agreements. These fees are not disclosed to the consumer (unless they are done verbally)

Can we do this - set our own fees (and not disclose them)? I'm thinking not.

1) No - I would bet your agreement with the issuing bank prohibits this. They probably have a revenue share agreement with you to cover your compensation... if that isn't enough, you need to renegotiate your contract with them.

2) No - a change in the terms of the agreement would require notification to the customers. You can't send that because it is not an agreement between you and the customer; it's between the issuing bank and the customer.

3) No - you'll get beat to death by UDAAP if you tell customers it's $5 to reload a card and then charge them $6 (or whatever).

Apparently, the Gift and Travel Cards are offered through FIS which uses The Bancorp Bank to issue the cards. We do not have an agreement with the Issuing Bank just FIS. The FIS site that the bankers use to open a card has OUR fee and OUR card limits included on the screen. Our Fee Schedule has "quoted" for Gift/Travel Card fees.