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I spoke to PayPal as well, asking if subscription sales, which I had been considering for one of my pay sites, would fall under the new IPSP/VISA regulations (this was before any news of MasterCard fees). Their reply was ambiguous- some subscription sales would be deemed subject to the enforcement of the new rules, some wouldn't. The message ended with "if you haven't received notification of additional fees, then they don't apply to your case and there's no need to worry".
Now, it's clear that it is NOT a matter of Visa requiring extra money from each and every account being processed by an IPSP, but only those that are flagged as "high risk" (read "adult industry"). This is why you don't find it on the "outside" of these third-party processing sites- it isn't a straight up deal and only SOME accounts are going to fall within this (arbitrary) group.
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