[jonpaul]

By "transactions fees", that's meant as a fee to the network. We don't make money off of that. We make money in the spread when you exchange.

[arcticbull]

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.

[mandelbrotwurst]

So you are collecting transaction fees, just none of one particular type of transaction fee.