Our bank charges $1.50 per month to customers who have a debit card. I see this as a covered transaction under Reg DD and required on the TISA disclosures and itemized on the checking account statement as part of the monthly SC recap. i.e. $2.00 maintence fee $2.30 per debit fee $1.50 monthly debit card fee
total: $5.80 fees.

(I don't believe this is clear in Reg DD as it does not address debit card fees- but I am assuming if it is required for ATM transactions, debit card transactions would be similiar).

I believe ATM card/check card fees are considered "maintenance fees" only if the card is issued automatically with an account; otherwise, it is a service separate from the account.

ATM and debit card fees are not considered maintenance or activity fees that prevent a bank from advertising an account as free (unless use of the card is mandatory to use the account). However, they are fees that have to be disclosed under 230.4 and 230.6, and under Reg. E, 205.9(b). Reg. E allows these fees to be separately disclosed on the statement, or aggregated (even with non-EFT fees). However, I'd say that the industry trend is toward more detail (less combining) on fees when it comes to statement time.

We are now going to start passing on the Visa Int'l Service Assessment or Foreign transaction fee of 1% (yes I know some are .08% but for simplicity sake let's use 1%) for all debit card transactions made at foreign merchants. In the past we just absorbed this fee.

Can someone confirm I'm on the right track and provide some guidance?

1) I know this is a Reg E fee and also a fee covered under Reg DD

2) I know I need to give an advance 30 day notice to my customer of the fee change (21 days under Reg E and 30 days under Reg DD). I will be doing that via a statement message.

3) This fee will post as a separate transaction so I need to make sure the description on the statement matches the description I use in my account opening disclosures and advance notice

4) Here is where I'm hung up...my vendor is providing me updated wording for my Reg E account opening disclosures that will basically tell the customer about the 1% fee. Is is enough to satisfy Reg DD requirements to have the fee verbiage disclosed in the Reg E portion of my disclosure or do I have to also include it on my fee schedule? I'm not sure if this is a similar type fee but we charge $1 for all non-network ATM withdrawals. That fee is disclosed in our Reg E disclosure but not on our fee schedule.

5) anything else I've forgotten? Most banks already did this when Visa made changes a few years ago.