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#1241990 - 08/31/09 01:58 PM Online Online Intra-Bank Transfers
reknab Offline
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not where I want to be
Our Online Banking provider is now offering Intra-bank transfers. A registered online banking customer can transfer funds to another registered online banking customer even though the receipeint is not on the donors account. If we decide to offer this do we need to add anything to our online banking discosure?

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eBanking / Technology
#1242451 - 09/01/09 12:57 AM Re: Online Online Intra-Bank Transfers reknab
rlcarey Online
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rlcarey
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Galveston, TX
IMHO - I think it is a bad idea. Any transfers of $3,000 or more will also be subject to the travel rule.
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#1242747 - 09/01/09 03:45 PM Re: Online Online Intra-Bank Transfers rlcarey
reknab Offline
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not where I want to be
Please, please, please correct me if I'm wrong....I didn't think the travel rule applied to transfers made to/from the same bank.

I HOPE I'm not wrong!!

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#1242758 - 09/01/09 03:50 PM Re: Online Online Intra-Bank Transfers reknab
rlcarey Online
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rlcarey
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Galveston, TX
Unfortunately, I have to burst your bubble:

103.33(e)(6) Exceptions. The following funds transfers are not subject to the requirements of this section:

(ii) Funds transfers where both the originator and the beneficiary are the same person and the originator's bank and the beneficiary's bank are the same bank.

Since the originator and the beneficiary are not the same person in this case, the Travel Rule applies.
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#1242786 - 09/01/09 04:03 PM Re: Online Online Intra-Bank Transfers rlcarey
John Burnett Offline
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John Burnett
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Cape Cod
If the accounts involved are consumer accounts, you have some added Reg E statement requirements, even if you can limit the transactions to under $3,000. You will have to include the name of the counterparty on the consumer statement (not just the account number).
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#1243012 - 09/01/09 06:47 PM Re: Online Online Intra-Bank Transfers John Burnett
reknab Offline
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Joined: Oct 2008
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not where I want to be
Online transfers are subject to reg E...correct? If so, than the intra-bank transfers would not be subject to the travel rule according to the statement below.

Only transmittals of funds equal to or greater than $3,000 (or its foreign equivalent) are subject to this rule, regardless of whether or not currency is involved. In addition, transmittals of funds governed by the Electronic Funds Transfer Act (Reg E) or made through ATM, or point of sale systems are not subject to this rule.

As for statement requirements as long as the last name/last four digits of donor account are on the recipients statement are we covered?

With commercial customers if we decide to allow online transfers between entities with different EIN but same ownership will the travel rule apply?

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#1243018 - 09/01/09 06:54 PM Re: Online Online Intra-Bank Transfers reknab
rlcarey Online
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rlcarey
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Galveston, TX
Nice catch - forgot to go look at the definition of a funds transfer.....
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#1243532 - 09/02/09 03:28 PM Re: Online Online Intra-Bank Transfers reknab
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted By: reknab


As for statement requirements as long as the last name/last four digits of donor account are on the recipients statement are we covered?

With commercial customers if we decide to allow online transfers between entities with different EIN but same ownership will the travel rule apply?


The Comment in the Official Staff Interpretations to Reg E says "Consumer as third-party payee. If a consumer makes an electronic fund transfer to another consumer, the financial institution must identify the recipient by name (not just by an account number, for example)." Theoretically, you could require that the originating consumer identify the receiving party and repeat that identification in the statement description. As for the statement information for the receiving party, you'd have to name the sending party, probably based on your CIF information, and I would not recommend including any of the sender's account number information.

If either party to the transfer is not a consumer, I think you have to be able to retrieve the information required by the funds transmittal recordkeeping rule.
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John S. Burnett
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