Q: For a card to be considered issued "in exchange for payment," must the issuer charge a fee in addition to the amount of funds loaded onto the card?
A: No. A card is issued "in exchange for payment" if a cardholder or other person provides funds to load on the card. The issuer or program manager need not charge an additional fee for issuance of the card to meet the "in exchange for payment" standard. (Added September 14, 2011)
This Q&A was obtained from FRB’s website, in a section for Regulation II (Debit Card Interchange Fees and Routing) Frequently Asked Questions, which may be found here: