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,

I do not believe it is required to be disclosed, but cannot see the harm in doing so.

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.

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.

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.