This just came to my attention yesterday! (Better late than never, I guess!) We already have the following disclosure in our Electronic Banking Agreement:
Any international purchases or ATM withdrawals will be withdrawn from the account in U.S. dollars. The exchange rate between the Transaction Currency and the Billing Currency is a wholesale market rate or the government-mandated rate in effect one day prior to the Central
Processing Date, and increased by one percent, plus or minus an additional percentage that the Bank determines.
The only major change I see is that Visa now determines the rate. Also, instead of showing up on our customer's statements as one lump sum, it shows up as separate charges.
Prior to April 1, 2005, the international fee was included in the dollar amount of the transaction. For instance, if the fee was $.92, and the withdrawal or purchase amount may have been $1.08; the client would see a single transaction of $2.00 on their statement.
Effective April 1, 2005, the fee is broken out from the transaction amount. This fee is NOT NEW, we are simply reporting it separately as we do the surcharge amount that the client sees on a domestic foreign ATM withdrawal. This supports the required disclosure of the fee as mandated by Visa.
I do not see this as requiring any disclosure under Reg E, as it is not a new fee, accrding to our disclosures, and is not an increase in an existing fee. Am I correct?
BC
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