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Step 1: Establish a Clear Surcharge Policy and Structure Before applying credit card surcharges, a Virginia MSP must develop a documented policy that outlines: The types of payments subject to surcharges How the fee is calculated (percentage or tiered) How your MSP complies with Virginia’s disclosure rules, card network limits, and federal restrictions like the Durbin Amendment You must also comply with the newly amended Virginia Consumer Protection Act , which, beginning July 1, 2025 , requires that any mandatory fees be clearly disclosed at the time prices are presented, not after

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