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#2238555 - 06/24/20 02:41 PM Reg E Initial Disclosure/Visa Rules
Auditgal Offline
100 Club
Joined: Dec 2014
Posts: 203
Hello,
I am sure this question has come up before and I tried to do some searching first but I am still unsure to the answer.

Visa rules have the Currency Conversion Rate disclosure and that is printed in the Visa debit card application; however, is it also required to be in the Reg E Initial Disclosure? I know that it "can" be included, but is it required and if so, can anyone tell me where it's written in the reg?

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#2238571 - 06/24/20 03:33 PM Re: Reg E Initial Disclosure/Visa Rules Auditgal
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,877
Illinois
It is required. See 1005.7(b)(5) and staff interpretations to that same citation:

(5) Fees. Any fees imposed by the financial institution for electronic fund transfers or for the right to make transfers.

3. Interchange system fees. Fees paid by the account-holding institution to the operator of a shared or interchange ATM system need not be disclosed, unless they are imposed on the consumer by the account-holding institution. Fees for use of an ATM that are debited directly from the consumer's account by an institution other than the account-holding institution (for example, fees included in the transfer amount) need not be disclosed. See § 1005.7(b)(11) for the general notice requirement regarding fees that may be imposed by ATM operators and by a network used to complete the transfer.
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