Our marketing group has posed the following question: Are we allowed to charge different foreign ATM surcharges for different blocks of machines? Or are we required to charge the same for all? Currently we charge non-customers a $1.50 ATM surcharge. The bank is considering raising the charge to $2 to be competitive with others in our area. Another concern is that we have a military base nearby and want to leave their ATMs at $1.50. I'm not sure operationally how this could be accomplished since this fee would only affect non-customers, but do we have disclosure concerns, would we have to post a notice of both fees? Thanks for any help.

205.16, especially (c)(2), will address that you need to disclose the fees.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.