Provision record
Bank of America · Bank of America Fee Schedule · View original document ↗

Foreign Currency Exchange Rate Discretion

Medium severity Medium confidence Explicit document language Unique · 0 of 352 platforms
Stay ahead of the changes
Track Bank of America and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Consumer impact (what this means for users)

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.

Cross-platform context

See how other platforms handle Foreign Currency Exchange Rate Discretion and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(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 …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • CFPB
    The CFPB enforces Regulation E's remittance transfer rules, which govern pre-payment disclosure requirements for international electronic fund transfers including exchange rate disclosures.
    File a complaint →

Provision details

Document information
Document
Bank of America Fee Schedule
Entity
Bank of America
Document last updated
May 5, 2026
Tracking information
First tracked
March 6, 2026
Last verified
Sept. 28, 2026
Record ID
CA-P-077651
Document ID
CA-D-00055
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a41616d76c047b51a94d2136b1b40626697034c2afd741cc707ee5d0e961b9e4
Analysis generated
March 6, 2026 20:47 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Bank of America
Document: Bank of America Fee Schedule
Record ID: CA-P-077651
Captured: 2026-03-06 20:47:54 UTC
SHA-256: a41616d76c047b51…
URL: https://conductatlas.com/platform/bank-of-america/bank-of-america-fee-schedule/provision/CA-P-077651/foreign-currency-exchange-rate-discretion/
Accessed: Oct. 2, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does Bank of America's Foreign Currency Exchange Rate Discretion clause do?

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.

How does this clause affect you?

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.

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.