Answer:
With the increase in examiner scrutiny for every sort of promotion featuring the word "free," I share your concern for using that term in connection with a fee-rebate program. Your customers will, in fact, be charged fees by the other ATM owners, and might even go overdrawn as a result. Somehow the word "free" doesn't fit, from my perspective.
My other concern is how your customers will obtain rebates. If your bank has a reliable procedure for identifying and rebating all those ATM surcharges, you should be OK (aside from my concerns for the use of "free"). However, if you are expecting your customers to request rebates for those fees, your regulator could feel you are engaging in deceptive or misleading advertising.
First published on BankersOnline.com 8/20/12
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