230.5 requires advance notice of changes to customers for certain changes in terms involving items to be disclosed in 230.4. We are increasing our wire fees. 230.4 Commentary says:

"2. OTHER FEES. Institutions need not disclose fees such as the following:
(i) Fees for services offered to account and nonaccount holders alike, such as travelers checks and wire transfers (even if different amounts are charged to account and nonaccount holders)."

I'm reading this to mean that wire fees are not covered if you make wires avaialble to both customers and non-customers. So, if we do not do non-customer wires (and we do not), any change in a fee that would be to the customer's detriment would have to be disclosed in advance. Am I reading this correctly?

I think this is a good question. I would say that the wire fee is incidental to an account though, and isn't a required cost the customer would have to pay, in order to have an account with you. Therefore, it wouldn't be disclosable under §230.4(b) or §230.5.

If it is a subsequent disclosure under .5, you would also be saying it is disclosable under (b)(4). Do you disclose it to new customers? If you do, a change notice would be appropriate.