💶MoraBanc Fees: From a No-Fee Account to Years of Increasing Charges — What My Experience and the AFA Record Show

A banking relationship with MoraBanc that began in 2003

I am a British citizen and have never lived in Andorra.

I first visited Andorra in 2003, specifically to open my bank account with MoraBanc. I have never returned to Andorra since that visit.

The original contractual documentation governing my account stipulated that there was no administration charge.

That was the contractual starting point of my banking relationship with MoraBanc.

Several years later, in 2009, administration charges began appearing on my account.

From that point onward, the charges did not remain static. They increased substantially over the following years and eventually became a very significant cumulative cost.

This raises a straightforward question:

How does a bank account originally opened under contractual terms providing for no administration charge evolve into an account carrying increasingly substantial administration commissions, and how was the customer informed of those changes?

This question is particularly relevant because I was not living in Andorra.

A customer who never lived in Andorra

My circumstances are particularly relevant when considering the question of how changes to banking charges were communicated.

I am a British citizen and have never been resident in Andorra.

My only visit to Andorra was in 2003, when I travelled there to open the account with MoraBanc.

I have never returned to Andorra.

From 2009 onward, I lived outside Andorra, first in Mexico and subsequently in Colombia.

I was therefore not a customer who periodically visited a MoraBanc branch in Andorra or routinely consulted physical banking documentation there.

This makes the distinction between publication of a tariff and communication with an individual customer particularly important.

The distinction became especially relevant in the subsequent examination of my complaint by the Autoritat Financera Andorrana (AFA).

The tariff booklet and the AFA's historical position

The AFA's correspondence concerning my complaint explains the regulatory position that existed before its Technical Communication No. 5/2020-SF of 9 April 2020.

According to the AFA, before that communication, MoraBanc was not generally required to inform customers individually of ordinary published tariffs and their modifications.

It was sufficient for the ordinary tariff to be available in a tariff booklet accessible to customers at the bank's public-facing branches, as well as through publication on the bank's website.

However, the AFA identified an important exception.

Where a customer benefited from a tariff lower than the published ordinary tariff, the customer had to be informed in advance and personally and reliably of any change to the tariff actually being applied to that customer.

That distinction is central to understanding what happened in my case.

MoraBanc Fees: From No Administration Charge to Increasing Commissions

The account history shows that administration charges began being applied in 2009, despite the original contractual position in 2003. Over the years that followed, the charges increased substantially.

The issue is therefore not simply whether MoraBanc had a published schedule of ordinary tariffs.

The questions are:

When were charges introduced?

What tariff was actually applied to my account?

When did that tariff change?

How was I informed of each change?

And, particularly where I was benefiting from a preferential tariff:

Was I personally and reliably informed before the change took effect?

These questions become particularly significant from 2019 onward because the AFA specifically examined the distinction between MoraBanc's ordinary tariff and the preferential tariff that was actually being applied to my account.

2019: the ordinary tariff and my preferential tariff

According to the AFA's examination, the ordinary administration tariff applied until the first quarter of 2019 was €700 plus IGI per quarter.

From 13 March 2019, the ordinary tariff increased to €2,500 plus IGI per quarter.

However, I was being charged €1,250 plus IGI per quarter, which was below the ordinary published tariff.

The AFA therefore considered that I had the status of a customer benefiting from a preferential tariff from that date.

For a broader examination of MoraBanc's contractual documentation, tariffs and administration commissions, see our analysis of MoraBanc's fees and contractual conditions.

That distinction is important.

Once a customer is paying a tariff below the ordinary published tariff, simply pointing to the existence of the ordinary tariff does not answer the question of whether the customer was properly informed when the tariff actually applied to his account was subsequently increased.

2020: the commission increased to €2,000 per quarter

During the first quarter of 2020, the administration commission applied to my account increased to:

€2,000 + IGI per quarter.

According to the documentation considered by the AFA, there was no evidence of a prior personal and reliable communication to me concerning this increase.

The AFA consequently stated that there had been:

“mala praxi (malpractice) per part de Mora Banc Grup, SA”

— in other words, malpractice by Mora Banc Grup, SA — in the application of this commission, at least throughout 2020 and the first half of 2021.

This is an important regulatory finding.

It is also important not to overstate it.

The AFA did not state that every administration commission charged to my account since 2009 was unlawful.

Its finding concerned the circumstances it examined, particularly the application and communication of the administration commission during the relevant period.

2021: another increase

During the first quarter of 2021, the administration commission increased again to:

€2,250 + IGI per quarter.

The AFA found that the only reliable communication documented was dated 9 April 2021, with the change taking effect on 14 June 2021.

The chronology was therefore significant.

The AFA concluded that there had been mala praxi (malpractice) in relation to the application of the administration commission during at least the period covering 2020 and the first half of 2021.

The AFA also considered the proportionality of the commissions

The AFA's findings went beyond the question of notification.

It referred to its Technical Communication No. 211/11 of 8 April 2011, which states that commissions should generally correspond to services actually provided that have been requested or firmly accepted by the customer.

The AFA also stated that commissions should maintain a proportion with the costs of the entity for the service provided and be in line with international standards.

In examining MoraBanc's response, the AFA stated that it had not been demonstrated that these commissions maintained proportionality with the entity's costs or were aligned with international standards.

The AFA explained that the bank's response did not justify the charges with real comparisons or comparisons with other financial centres.

This is a significant observation, although it is important to understand exactly what the AFA did and did not decide.

The AFA did not determine that the commissions were legally abusive or disproportionate in the judicial sense. It expressly stated that such a determination was a matter for the judicial authorities.

Another problem identified in the 2021 documentation

The AFA identified a further issue concerning the administration commission in the new 2021 account documentation.

The relevant tariff information stated that the €2,250 + IGI quarterly administration commission would be waived provided that certain conditions were met.

The document referred to information about those conditions being annexed at the end of the tariff table.

However, according to the AFA, those conditions did not actually appear where the document said they would.

The explanations provided by MoraBanc were not located in the annex where the conditions should have appeared.

The AFA therefore also identified mala praxi (malpractice) concerning the application of the administration commissions for the last two quarters of 2021, and subsequently if the conditions had not been correctly communicated.

The difference between a published tariff and notification

This is, in my view, one of the most important lessons from my experience with MoraBanc.

A bank can publish a tariff.

A tariff can be available in a branch.

A tariff can be published on a website.

But those facts do not necessarily answer a different question:

What tariff was actually being applied to a particular customer, and was the customer properly informed when that tariff changed?

The distinction becomes especially important where the customer was benefiting from a preferential tariff below the bank's ordinary published tariff.

The AFA's findings make clear that, in those circumstances, prior personal and reliable communication was relevant.

For customers living permanently abroad, this issue becomes even more significant.

What does this mean for customers who live abroad?

My experience raises a practical question for international banking customers.

A customer may live thousands of kilometres from the country in which the bank is located.

They may never visit the bank's branches.

They may manage the account entirely from another country.

In my case, I opened the account in Andorra in 2003 and never returned to the country.

From 2009, I was living abroad, first in Mexico and later in Colombia.

For someone in that position, the practical importance of direct communication concerning changes to the charges applied to an account is obvious.

The question is not merely whether information existed somewhere.

The practical questions are:

What changed?

When did it change?

What tariff was actually applied?

How was the customer informed?

When was the customer informed?

And where a preferential tariff was involved:

Was the customer informed personally and reliably before the change took effect?

For a broader overview of the Andorran banking system, regulation, commissions, non-resident banking and consumer considerations, see [Banks in Andorra: What Customers Should Know Before Banking in Andorra].

Why the original 2003 contract matters

Long-term banking relationships can last for decades.

Over such a period, the current tariff schedule may tell only part of the story.

The original contract can be equally important.

In my case, the banking relationship with MoraBanc began in 2003, with contractual terms providing for no administration charge.

Administration charges subsequently appeared from 2009 and increased over the years.

The historical account records therefore provide an important chronology against which the later contractual and tariff documentation can be considered.

The question is not simply what MoraBanc's tariff was in any particular year.

It is also how the relationship evolved from its original contractual terms.

What the AFA did — and did not — decide

It is important to distinguish between my own experience and the findings of the regulator.

The AFA did not declare that every commission charged to my account since 2009 was unlawful.

It did not determine that every commission was abusive.

It did not determine contractual damages.

It expressly explained that its reports concerning customer complaints do not have the character of a final determination of contractual responsibility, which remains a matter for the courts.

What the AFA did do was examine the particular complaint and documentation presented to it.

Its findings included an express conclusion of mala praxi (malpractice) concerning the application of the administration commission during at least 2020 and the first half of 2021.

It also found that the proportionality of the relevant commissions with the bank's costs and their alignment with international standards had not been demonstrated in MoraBanc's response.

And it identified an additional problem concerning the communication of the conditions attached to the administration-fee exemption in the 2021 documentation.

Those findings should speak for themselves.

What customers should check before opening or maintaining an account

My experience suggests that customers — particularly international and non-resident customers — should retain and carefully examine their banking documentation.

1. Keep the original contract

Do not rely solely on the bank's current terms and tariff schedule.

The original agreement may contain provisions that are no longer apparent from current documentation.

2. Establish when charges first appeared

If an account originally carried no administration charge, determine when that charge first appeared in the account history.

3. Compare the tariff with what you actually paid

The ordinary published tariff may not necessarily be the tariff actually applied to your account.

4. Keep evidence of communications

Retain letters, emails, contractual amendments and other notifications concerning changes in charges. MoraBanc online banking can also be useful for reviewing account statements, transaction history and digital communications when reconstructing the history of charges. Dates can be critical.

5. Pay particular attention to preferential tariffs

If you are paying less than the ordinary published tariff, establish precisely what happens if the bank proposes to increase your individual tariff.

6. Ask what each commission represents

Customers should understand what service a commission relates to and what contractual or tariff provision provides for it.

7. Check the regulator

Customers should distinguish between information supplied by a bank and requirements or findings established by the relevant financial regulator.

A broader question about banking transparency

My experience raises a question that is increasingly relevant to international banking.

Customers frequently live in one country, hold financial relationships in another and manage their accounts remotely.

For such customers, effective communication is particularly important.

A physical tariff booklet in a foreign branch may be of limited practical relevance to someone who lives thousands of kilometres away and has never returned to the country where the account was opened.

The modern question should therefore not simply be:

“Was the tariff published?”

It should also be:

“Was the customer clearly informed of the tariff that was actually going to be applied to his account?”

That distinction is fundamental to transparency.

An independent account of a documented MoraBanc experience

I am publishing this account because my experience illustrates issues that may be relevant to other customers with long-term banking relationships, particularly those who live outside the country where their bank is located.

This article does not claim that all banks in Andorra operate in the same way.

It does not claim that every commission charged to my account was unlawful. And it does not attempt to determine matters that the AFA itself reserved for the judicial authorities.

Instead, it sets out a documented chronology and places it alongside the findings made by the AFA when specific aspects of the administration commissions and their communication were examined.

The starting point is straightforward:

I am a British citizen who never lived in Andorra. I visited Andorra once, in 2003, to open my MoraBanc account, and I have never returned. The original contractual terms provided for no administration charge. Administration charges subsequently appeared from 2009 and increased substantially over the years.

I was living abroad during this period.

And when the AFA later examined specific aspects of the administration charges and their communication, it expressly identified instances of “mala praxi (malpractice).”

For me, the broader lesson is simple:

When maintaining a long-term banking relationship, do not look only at the tariff a bank publishes today. Keep the original contract, examine the historical charges, record when fees change, and establish how and when you were actually informed.

Important disclaimer

This article describes a specific customer's experience and discusses findings contained in correspondence from the Autoritat Financera Andorrana (AFA). It is intended as an independent, fact-based account and does not constitute legal or financial advice.

The term “mala praxi” (malpractice) is used because it appears in the AFA's findings concerning the specific circumstances examined. It is not intended as a general allegation concerning all banks or all banking relationships.

This article does not disclose or discuss the terms of any subsequent agreement between the parties.

Readers with questions concerning their own banking relationship should obtain independent professional advice and consult their own contractual, account and regulatory documentation.