A transfer is priced in two places at once. There is a fee, which is usually stated, and there is the gap between the rate applied and the market midpoint, which usually is not. The ACCC’s inquiry into foreign currency services found the second one hard for people to see at all: it reported that comparing prices is difficult because some suppliers do not disclose their total price up front.
Which of the two dominates depends on the amount. A flat fee is a large share of a small transfer and a trivial share of a large one, while a margin scales with the amount being converted, so it barely registers on a small transfer and becomes the main cost on a big one. Two services can therefore swap places depending only on how much is being sent, with nothing about either of them having changed.
The two are also disclosed on different schedules. A fee is a number a supplier can publish in advance. A margin only becomes visible by comparing the rate applied against the market midpoint at the moment of conversion, which is a calculation nobody is prompted to do and which cannot be done afterwards from a receipt. That asymmetry is what the ACCC’s Best Practice Guidance was aimed at, and adherence to it is what the regulator credits with making genuine comparison possible where it previously was not.
That leaves one comparable number. Not the rate quoted, not the fee, but the amount that reaches the recipient - which the ACCC treats as the best representation of value.
