PayPal · PayPal User Agreement

Currency Conversion and Exchange Rate Markup

Medium severity
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What it is

PayPal applies its own exchange rate — which includes a markup above the base market rate — when converting currencies, and users agree to these rates by using the service, with full rates disclosed on separate fee pages rather than in the main agreement.

Consumer impact (what this means for users)

When you send or receive money in a foreign currency, PayPal applies its own exchange rate that includes a markup — meaning you receive less than the mid-market rate — and the specific percentages are disclosed only on separate fee pages rather than in the main agreement you sign. For frequent international transactions, this markup can result in materially higher costs than alternative payment methods.

Cross-platform context

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Why it matters (compliance & risk perspective)

Currency conversion markups can significantly increase the effective cost of international transactions, and routing users to external fee pages rather than disclosing rates in the main agreement makes it harder for consumers to understand the true cost before transacting.

View original clause language
By opening and using a PayPal account, you agree to comply with all of the terms and conditions of this user agreement, including the Fee pages, and any upcoming changes described on the Policy Updates page at the time you accept this user agreement.

Institutional analysis (Compliance & legal intelligence)

(1) REGULATORY FRAMEWORK: Currency conversion fee disclosures are governed by Regulation E (12 CFR Part 1005.31) for remittance transfers over $15, which requires upfront disclosure of exchange rates and fees before the consumer authorizes the transaction. The CFPB's Remittance Transfer Rule applies when PayPal facilitates international transfers. FTC Act Section 5 applies if conversion costs are not adequately disclosed. EU users are separately protected by the EU Payment Services Directive (PSD2) but are outside scope of this agreement. (2)

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Applicable agencies

  • CFPB
    The CFPB enforces the Remittance Transfer Rule (Regulation E Subpart B) requiring clear disclosure of exchange rates and fees for international money transfers.
    File a complaint →

Provision details

Document information
Document
PayPal User Agreement
Entity
PayPal
Document last updated
March 24, 2026
Tracking information
First tracked
April 18, 2026
Last verified
April 27, 2026
Record ID
CA-P-003275
Document ID
CA-D-00044
Evidence Provenance
Source URL
Wayback Machine
SHA-256
272be32ad840cc4b421beb9c5dd9d378a2fd1f23c24ebe4d0ca1310215ea5b10
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: PayPal | Document: PayPal User Agreement | Record: CA-P-003275
Captured: 2026-04-18 08:41:49 UTC | SHA-256: 272be32ad840cc4b…
URL: https://conductatlas.com/platform/paypal/paypal-user-agreement/currency-conversion-and-exchange-rate-markup/
Accessed: April 29, 2026
Classification
Severity
Medium
Categories

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