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#1920582 - 05/07/14 12:13 AM "Designer" ATM card - Reg E
fmb Offline
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Joined: Sep 2003
Posts: 97
Customers can upload a favorite pic to use as their ATM card background. There is a fee that comes with this IF the customer chooses to use their pic rather than the generic background chosen by the bank. Must this fee be disclosed on the Reg E disclosure? Thanks.

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Operations Compliance
#1920709 - 05/07/14 03:03 PM Re: "Designer" ATM card - Reg E fmb
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I could argue either way, but I think it's technically correct to say that, since the designer card isn't a necessity to obtain the EFT service, you could leave it out.

That said, with all the current gnashing of UDAP teeth over transparency in disclosures of things like fees, why bother to argue the point? Include the fee in your disclosures so that no one can make an issue over it.
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