We would like to charge a rush fee when customers call in for a rush request for a new debit card (mostly for cost of next day air). We would inform the customer of the fee before we process the request so they could decide if they want to go forward.
Is this a fee under Reg. DD that would require disclosure in advance?

Not DD, but E is what you need to worry about. But if it is a truly an optional charge and disclosed at the time of selection of the expedited service by the customer, I don't think you need to include it.

Ours is on our fee schedule as a courtesy when they open the account.

Thanks Randy, much appreciated!

I just learned we have an option of sending the card to a different address when ordering "rush delivery" doesn't this violate the duties of card issuers? I am not seeing anything specific in applicable policies that this would be allowed.

I think it does fly in the face of Red Flag, but that argument goes away really fast when you have a consumer who has traveled out of the area and whose debit card is lost/stolen or compromised and they neglected to bring any other payment form with them. I have had this conversation twice.

You need to have compensating methods to mitigate the risk in sending a card to that other address by making very sure you know who is making the request and that it's not under duress. Sometimes you'll already know the customer is traveling out of the area because he's provided you a travel advisory, but don't let that knowledge lull you into a false sense of security. Carefully check out the identity of the person making the request.

Thank you John! We do have other methods too because the circumstance I have given has happened more than once.