Provision record
Bank of America · Bank of America Deposit Agreement · View original document ↗

All-In Foreign Currency Exchange Rate with Undisclosed Profit Markup

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Document Record

What it is

The agreement states that Bank of America applies an all-in exchange rate to foreign currency transactions that may include profit, fees, costs, and mark-ups determined at the bank's sole discretion, which may vary by customer, transaction method, timing, and amount, and that the bank disclaims all liability for exchange rate outcomes.

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This analysis describes what Bank of America's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes the bank to embed undisclosed profit and variable mark-up into foreign currency exchange rates applied to customer transactions, with the rate and mark-up level determined solely by the bank and potentially differing across customers and transaction types, while disclaiming all liability for rate outcomes.

Recent Activity

This document changed recently

High Jul 12, 2026

The updated Deposit Agreement now explicitly discloses that disputes are subject to mandatory arbitration and class action waiver provisions, as stated prominently at the document's opening. The agreement establishes separate dispute resolution procedures for personal and business accounts and introduces new operational provisions governing account closure, jurisdiction and venue, cutoff times for legal orders, and responses to conflicting demands. The terms require that by using or maintaining your account after a change is effective, you agree to be bound by the updated provisions. You can review the complete updated agreement on bankofamerica.com or contact Bank of America directly if you wish to understand how the specific dispute resolution procedures apply to your account.

View change record →

Consumer impact (what this means for users)

Under this provision, any transaction conducted in a foreign currency is subject to an exchange rate that may include profit and mark-up components determined by the bank without prior notice, and which may differ across customers, transaction methods, locations, and amounts. The agreement states the bank disclaims all direct, indirect, and consequential liability for its exchange rates.

Cross-platform context

See how other platforms handle All-In Foreign Currency Exchange Rate with Undisclosed Profit Markup and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
We will apply an all-in exchange rate, meaning that the exchange rate applied to your transaction may include profit, fees, costs, charges or other mark-ups designed to compensate us as determined by us in our sole discretion. The level of such profit, fees, costs, charges, or other mark-ups may differ for each customer and may differ for the same customer depending on, among other things, the service or method used to execute the transaction, the timing or location of transaction execution, the payment media (including but not limited to bank notes, checks, wire transfers, etc.), or amount of the transaction. We do not accept any liability for our exchange rates. Any and all liability for our exchange rates is disclaimed, including without limitation direct, indirect or consequential loss.

Excerpt from Bank of America's Deposit Agreement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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Applicable agencies

  • CFPB
    The CFPB enforces Regulation E Subpart B governing remittance transfer disclosures and holds UDAAP authority over foreign currency exchange rate disclosure practices at consumer financial institutions
    File a complaint →
  • FTC
    The FTC holds authority over unfair or deceptive acts or practices in connection with undisclosed fees and variable pricing in consumer financial services transactions
    File a complaint →

Provision details

Document information
Document
Bank of America Deposit Agreement
Entity
Bank of America
Document last updated
May 5, 2026
Tracking information
First tracked
Sept. 23, 2026
Last verified
Sept. 23, 2026
Record ID
CA-P-077593
Document ID
CA-D-00053
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3cb669a13483772d724da0728bab13900badf9ceb665aacfd63576c8b6c97363
Analysis generated
September 23, 2026 01:55 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Bank of America
Document: Bank of America Deposit Agreement
Record ID: CA-P-077593
Captured: 2026-09-23 01:55:22 UTC
SHA-256: 3cb669a13483772d…
URL: https://conductatlas.com/platform/bank-of-america/bank-of-america-deposit-agreement/provision/CA-P-077593/all-in-foreign-currency-exchange-rate-with-undisclosed-profit-markup/
Accessed: Sept. 26, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Bank of America's All-In Foreign Currency Exchange Rate with Undisclosed Profit Markup clause do?

This provision authorizes the bank to embed undisclosed profit and variable mark-up into foreign currency exchange rates applied to customer transactions, with the rate and mark-up level determined solely by the bank and potentially differing across customers and transaction types, while disclaiming all liability for rate outcomes.

How does this clause affect you?

Under this provision, any transaction conducted in a foreign currency is subject to an exchange rate that may include profit and mark-up components determined by the bank without prior notice, and which may differ across customers, transaction methods, locations, and amounts. The agreement states the bank disclaims all direct, indirect, and consequential liability for its exchange rates.

Is ConductAtlas affiliated with Bank of America?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Bank of America.