Assuming that the card meets the definitions for a "general-use prepaid card" in Regulation E ยง 1005.20(a)(3) and isn't subject to any of the exceptions in that section, the fee you ask about would be covered by .20(d)(2), and therefore is required to be disclosed on the card.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8