You say you don't collect transaction fees, but that you make a small amount of money off the spread. I'm confused, whats the difference between these two?
So by that logic, the airport Travelex that charges "no commission" but a 20% spread between the bid and the ask is also not charging transaction fees? I suspect cribbing from Travelex and calling it "no commission" is likely both more accurate, and probably more legal, but IANAL.