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