Bank of America discloses that it determines foreign currency exchange rates at its sole discretion, that markups are included in those rates, and that the bank derives revenue from currency conversion on both outgoing and incoming international wire transfers.
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
This provision discloses that the total cost of international wire transfers includes not only the stated wire transfer fees but also an undisclosed markup embedded in the exchange rate, and that the bank retains discretion over the magnitude of that markup for each transaction.
Interpretive note: The practical application of this clause depends on whether specific transactions qualify as remittance transfers under Regulation E and whether the bank's pre-payment disclosure process satisfies the regulatory requirements, which cannot be determined from this document alone.
Under this clause, customers sending or receiving international wire transfers in foreign currency are subject to exchange rate markups that are set by Bank of America at its sole discretion and are not disclosed as a fixed fee amount; the document acknowledges the bank derives revenue from currency conversion in addition to the stated wire transfer fees.
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Compare across platforms →"In addition to any applicable wire transfer fees, there are markups associated with the currency conversion included in our exchange rate and we make money from the foreign currency exchange. Exchange rates are determined by Bank of America at its sole discretion. Incoming wire transfers received in a foreign currency for payment into your account will be converted into U.S. dollars using the applicable exchange rate determined by Bank of America at its sole discretion.Excerpt from Bank of America's Fee Schedule
(1) REGULATORY LANDSCAPE: International wire transfer fee disclosure requirements under Regulation E's remittance transfer rules require covered institutions to disclose the exchange rate, all fees charged, and the amount to be received by the recipient …
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This provision discloses that the total cost of international wire transfers includes not only the stated wire transfer fees but also an undisclosed markup embedded in the exchange rate, and that the bank retains discretion over the magnitude of that markup for each transaction.
Under this clause, customers sending or receiving international wire transfers in foreign currency are subject to exchange rate markups that are set by Bank of America at its sole discretion and are not disclosed as a fixed fee amount; the document acknowledges the bank derives revenue from currency conversion in addition to the stated wire transfer fees.
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