One important part of the banking and finance sector given a relatively brief examination at the royal commission into into misconduct in the banking industry was credit cards - specifically transaction fees for international transactions made via credit cards.Citi has responded to the first round of hearings by noting the commission's proposed factual findings on international transaction fees "do not, with respect, correctly record what happened."The case study presented to the commission looked at MasterCard's changes to its rules in September 2014. Issuers including Citi were to be charged a fee on cross-border transactions where "a cross-border transaction refers to any transaction on the MasterCard… In which the cardholders country code differs from the country code of the merchant."Citi said MasterCard's language was technical in nature, and was not communicating with consumers. The bank noted that Visa used similar wording - that is, referencing different country codes.In 2016, a review of the industry by ASIC saw Citi the regulator and the Australian branch of the global bank in disagreement.ASIC considered that Citi needed to specifically disclose situations where the fee applied although the wording was not precise in technical terms it described in three bullet points situations where it was likely to happen.Hence the main point of Citi's submission was that the dispute came down to a matter of interpretation and semantics as to whether or not it had accurately described situations where this fee would be charged in a way customers would understand.Citi also pointed out that it had agreed to refund fees in certain circumstances which, strictly speaking, it need not have done - situations where a customer made a purchase or the website accessible from Australia but were not aware the merchant was an overseas merchant.Citi said it approached the matter conservatively so that a refund was given whenever a merchant had both a ".com" and a ".com.au" domain name.Citi therefore disputed that its behaviour amounted to misconduct and also noted that it was denied procedural fairness. Citi said it was in a "somewhat unusual position in that the commission did not require its key witness, Alan Matchet, (formerly Citi's head of cards and loans, now Citigroup's head of retail banking for Australia) for cross-examination."His [written] statement only provided evidence in answer to the commission's specific list of questions and had he turned up to be an expert witness, extra evidence may have come out that would have allayed concerns that Citi did not have proper processes for a variation of terms in its credit cards," Citi's submission read.Citi instead requested that the proposed finding of misconduct be replaced by a related finding that Citi failed to have adequate processes - even though the early part of its submission explained why its procedures were clear.The Citi submission pointed out that the NCCP Act envisaged breaches that were more systemic than one unintentional mistake, and argued this case study arose due to "well-intentioned but deficient drafting", and was "an isolated event", rather than "a plan or pattern