We'd like to start accepting debit card payments through the Visa program to make a loan payment and would like to be able to charge the customer for making their payment this way.

1. The fee is to cover our costs, but can we upcharge? For example, if our interchange fee is 65 cents, can we charge the customer $2.00?
2. If we can charge, would it be a finance charge?
3. How would we disclose the fee since it will only be charged if they use a debit card? Does it need to go on the TIL?

You should know that the CFPB is looking at these "pay-to-pay" convenience charges as potentially a UDAAP issue. While the guidance is directed at debt collectors, I don't think it would take much for them to look at it from the banking side.

It most likely costs you as much if they write you check to process it. Why bother and risk the UDAP.?

Thanks for the feedback!