I just went to the CFPB credit card site (
https://www.consumerfinance.gov/credit-cards/agreements/) and grabbed 3 different card types from six different large card issuers (but only one from Discover because that's all they had) (
https://www.nilsonreport.com/publication_chart_of_the_month.php?1=1&issue=1081). I pulled the credit card disclosures, saved them and then logged all of the fees disclosed in a spreadsheet. We don't have very many fees and ours are all lower than those I looked at, so I called it good. But I figure this way if anyone asks how I determined it was "bona fide" I have a spreadsheet and copies of other institutions disclosures to back it up.
I interpret the card reorder fee as a the same type of fee as a late fee and don't think it should be included in the MAPR nor does it need to be determined if it is "bona fide." Not sure if regulators will agree with me, but without any clarification... Also in the Interpretive Ruling it says the DOD believes information on credit card fees are "widely available." So if I can't find them by looking at 16 different card types, I feel just a bit more justified.
Obviously, this is how we are choosing to interpret MLA until told otherwise... And if a regulator can offer some guidance, we will take it!
But I am definitely all ears if someone can point out something that I am missing!