We are getting ready to begin Bill Pay in the near future and wanted some guidance over a couple of items.

1. Our third party service provider can either automatically turn on Bill Pay for any customer who has Internet Banking or we can require customers to sign up for Bill Pay. Should we have customers sign up for Bill Pay in order to get the disclosure for the charges out there? (this also goes in line with the 2nd and 3rd question)
2. What disclosures are needed for Bill Pay and do these need to be issued in advance of the roll out to existing customers and put in other disclosures for those who sign up from the date of roll out forward?
3. Do these charges need to be a part of the disclosure?
We are going to charge $.50 for all bill payments over 15 a month. Also, our third party service provider will charge the bank a $20.00 charge for returned checks due to insufficient funds and we will pass that charge on to the customer along with the bank's normal NSF charge. If so, where is the best place to reflect these charges? In the Internet Banking disclosure?
All input is greatly appreciated.

1. You will want a specific bill pay agreement and signup procedure.
2. New product, new signup even for existing customers.
3. You will need to disclose the fees somewhere. We use a current fees and charges document so it can be updated with changes. We mail it to the customer upon approval for fill pay and before they go active. Your bill pay agreement can refer to it.

Thanks for the reply SJB. The one problem I am running into is let's say our overdraft charge is 28.00. The provider of the bill pay also will charge the bank 20.00 for any overdraft. This fee will be passed to the customer. So, we are not only charging the 28.00 bank fee, but the customer will also get charged the 20.00 from the thrid party, total of 48.00. Now, in our normal fee schedule we disclose the 28.00, but not the addiitonal 20.00 from the thrid party when bill pay is utilized. How should we disclose?
Or, on the other side of this, the bank's stop payment fee is $20.00. The provider of the bill pay will charge the bank $25.00 for any stop payment order. However, in this case, the bank will not charge the bank's $20.00 stop pay fee because the records to be stopped are not on the bank's system. Instead, only the bill pay provider fee of $25.00 will get charged. Here again though, how do we disclose this?
How do others disclose this?

Let's make it simple - do you disclose the fees and the amounts that are charged by the third party bill pay service provider that will be passed on to the customer, i.e. additional NSF and stop payment fees, or can you just state the fact that additional fees may be charged by the bill pay serivce provider?