I understand this to mean that the cost of a transaction would be notified to a customer at the time of the transaction rather than being notified to them at the end of the two or three month billing period.
The European Communities (Payment Services) Regulations 2009 (PSR) and the Consumer Protection Code 2012 contain certain requirements in relation to the information to be provided about charges to ensure that the customer is aware in advance of the amount of a charge for the provision of certain services.
The PSR require that payment service providers:
- provide information on all charges payable by the user to the provider and, where such charges can be broken down into components, a statement of those components.
- agree, between the payment service user and the payment service provider, any charges imposed. These charges shall be appropriate and in line with the payment service provider’s actual costs.
- provide information on all charges applicable before a user uses a payment service.
The Consumer Protection Code 2012 (the Code) contains a number of provisions relating to charges which regulated entities including credit institutions must comply with, except when providing a payment service and/or issuing electronic money. Under the Code regulated entities must:
- make full disclosure of all relevant material information, including all charges, in a way that seeks to inform the customer.
- provide consumers with a breakdown of all charges, including third party charges prior to providing a product or service to the consumer. Where such charges cannot be ascertained in advance, notify the consumer that such charges will be levied as part of the transaction.
- display a schedule of fees and charges in public offices, in a manner that is easily accessible to consumers. If the regulated entity has a website, its schedule of fees and charges must also be made available on the website.
- notify affected consumers of increases in charges, specifying the new charge and the old charge, or the introduction of any new charge, at least 30 days prior to the change taking effect.
- where charges are accumulated and applied periodically to accounts and amount to €10 or more, notify the consumer at least 10 business days in advance of the deduction of the charges and give each consumer a breakdown of such charges.
I can see how the premise of the question could operate for a cash withdrawal from the specific bank's ATM when the transaction is taking place. However, I am not clear how this could operate in the case of for example a debit card purchase where the bank's technology is not necessarily being used. Nor am I clear on how it would operate when another ATM network is being used or in the case of an internet transaction on a third party website.
I am satisfied that consumers are in a position to inform themselves of the charges that they are likely to incur but there is always room for greater transparency. For example, I am aware of certain financial service providers who use technology to provide additional information to customer by sending a text message when they are in danger of becoming overdrawn. If customers are unhappy with their financial service provider for any reason, including cost or information provided, they have the right to switch to a different provider.
In this regard, I would encourage customers to look at my Department's website www.switchyourbank.ie which provides useful information on switching financial products.