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#1609379 - 09/27/11 05:01 PM Travel Rule
pweiss Offline
100 Club
Joined: Mar 2011
Posts: 103
CA
Good Morning,

Are we required to disclose the Travel Rule in our wire transfer disclosure and our e-banking disclosures (we have a gift registry and a pay-a-friend service we offer)?

Thanks,
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Phil Weiss, CAMS

My opinions are my own and not that of my employer.

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#1609391 - 09/27/11 05:10 PM Re: Travel Rule pweiss
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
I do not believe it is required to be disclosed, but cannot see the harm in doing so.
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#1609865 - 09/28/11 04:05 PM Re: Travel Rule J2C
pweiss Offline
100 Club
Joined: Mar 2011
Posts: 103
CA
After digging around, I found that the e-banking services do not follow the Travel Rule as they fall under Reg E. However, I couldn't find any guidance on whether or not you need to disclose the Travel Rule in your wire transfer disclosure. Unless I see or hear otherwise I won't tweak the current disclosure.
_________________________
Phil Weiss, CAMS

My opinions are my own and not that of my employer.

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#1610306 - 09/28/11 11:06 PM Re: Travel Rule pweiss
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,288
Galveston, TX
The Travel Rule is purely a recordkeeping requirement inmposed on the bank. I'm not sure why anyone would go out of the way to cover this in a customer disclosure.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1610349 - 09/29/11 11:38 AM Re: Travel Rule pweiss
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
BSA does not require anything in the way of disclosures other than the notice related to CIP and identification. That is not its function.

I'm not aware of any required disclosures for wire transfers. If there is no explicit requirement for it, I would probably consider eliminating it rather than tweaking it.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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