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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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8