Proof of payment

I am looking at §1005.31(b)(3) and the proof of payment banks are required to send. I just want to clarify my understanding and see how other banks/institutions deal with this requirement.

We send the combined disclosure and give the customer 30 minutes to cancel the wire. So even if we send the combined disclosure to the customer, we have to provide a proof of payment once the wire has been completed? If I am reading the Reg correctly, it can be the exact same combined disclosure, but the date/time of the transfer have to be added?? Can anyone clarify this for me?

Yes; see Comment 31(b)(3)-1. You can annotate the combined disclosure to add the payment confirmation or you can issue a separate receipt. For my perspective, this sort of makes the idea of a combined 31(b)(1) pre-payment disclosure and 31(b)(2) receipt a waste of effort, since something more remains to be added if a 31(b)(3) combined disclosure is used.

I guess it just provides a little more flexibility in how the disclosures and receipts are handled.

Thank you for the response. Guess I wasn't really sure why the Reg gives you an option for a combined disclosure if you have to provide a receipt after the fact anyway...

I suppose it's so a provider doesn't have to provide two different forms.

I know this is an older thread, but can someone add some insight on the Combined Disclosures Official Interpretation regarding "Confirmation of Scheduling"? We use a combined disclosure - and when I read this paragraph in the official interpretation Comment 2 to 31(b)(3) Confirmation of Scheduling - it states we can provide this confirmation in lieu of proof of payment - but, I can't find a definition of a "Confirmation of Scheduling". Is that just referring to the effective date of the remittance that is on the Combined Disclosure? That's probably WAY too simple to be true.

Any help is greatly appreciated

I'm bumping this just to see if anyone can help me with my question -