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#1654226 - 01/23/12 03:11 PM CFPB final Reg E remittance transfers
ahou Offline
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ahou
Joined: Aug 2002
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Ugh. I've been dreading the day CFPB would implement this rule.
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#1654325 - 01/23/12 04:44 PM Re: CFPB final Reg E remittance transfers ahou
gonetobeach Offline
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gonetobeach
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near Dallas
Me too! And am I correct in thinking this applies to us all....not just 10B and above?

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#1654330 - 01/23/12 04:47 PM Re: CFPB final Reg E remittance transfers gonetobeach
mtngrrl Online
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mtngrrl
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Northern California
Originally Posted By: gonetobeach
Me too! And am I correct in thinking this applies to us all....not just 10B and above?


Yeah, but don't feel bad. It also applies to non-FI money transmitters. They're looking at a safe harbor for institutions/organizations that only do a few per year (proposed at 25 transfers in the last year). Otherwise, we're all in it together!
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#1654402 - 01/23/12 05:43 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
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They do sneak up on you!. I found a news release on this, but haven't yet received a notice. Thanks for the heads up!
Last edited by John Burnett; 01/23/12 05:46 PM.
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#1654528 - 01/23/12 07:38 PM Re: CFPB final Reg E remittance transfers John Burnett
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So will this be effective one year from today's publication? Or is it one year from the original publication? Does anyone know for sure?

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#1654569 - 01/23/12 08:05 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
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One year from when it gets published in the Fed Register, which should be in a couple/few days.
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#1654582 - 01/23/12 08:24 PM Re: CFPB final Reg E remittance transfers ahou
Aggs Offline
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Hoosier Country
Link to summary:
http://www.consumerfinance.gov/regulations/final-remittance-rule-amendment-regulation-e/

Link to final rule in the Federal Register:
http://www.consumerfinance.gov/assets/do...2020%202012.pdf

Just FYI. I already had to get the links for my supervisor, so I thought I'd share here. grin
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#1654608 - 01/23/12 08:25 PM Re: CFPB final Reg E remittance transfers John Burnett
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Thanks so much. That is how I should have said it and what I was hoping and thinking would be the case.

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#1654722 - 01/23/12 11:23 PM Re: CFPB final Reg E remittance transfers ahou
EmilyAnn Offline
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Does anyone know if BOL will be holding a webinar on the new foreign remittance rule? I looked at the Learning Connect calendar for the next few months, but didn't see anything. Maybe something will be in the works now that the rule has been finalized???

Also, I was reviewing the model notices in the final rule with our Operations Officer. We agreed that we would likely need to develop a fill-in form for the pre-transaction disclosure and receipt. We don't have an automated solution for developing these kinds of disclosures (and thankfully, we don't have a lot of volume in this area).

In any case, is anyone aware of an automated solution? Or whether the forms vendors or teller platforms might tackle it? We haven't heard anything from them, but will certainly be checking with our vendors.

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#1654744 - 01/24/12 12:43 AM Re: CFPB final Reg E remittance transfers ahou
Andy_Z Offline
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Nothing scheduled yet that I know of. How many bankers are that interested in a 2 hour webinar?
Last edited by Andy Z; 01/24/12 12:44 AM.
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#1654857 - 01/24/12 02:34 PM Re: CFPB final Reg E remittance transfers EmilyAnn
John Burnett Offline
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If you use a vendor in this line of business, you should ensure that the vendor is aware of the new requirements and that they will be effective a year from now. Then start pushing for regular progress reports on updating the vendor software, forms, etc., to meet the January deadline.
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#1655147 - 01/24/12 07:23 PM Re: CFPB final Reg E remittance transfers Andy_Z
EmilyAnn Offline
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Originally Posted By: Andy Z
Nothing scheduled yet that I know of. How many bankers are that interested in a 2 hour webinar?


For the record, we would definitely be interested. We're familiar with Reg E of course, but now that it's been expanded to include this previously uncovered area, we'd love some expert guidance.

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#1656398 - 01/26/12 04:17 PM Re: CFPB final Reg E remittance transfers ahou
Doug Hendrickson Offline
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Do I understand correctly that we would be considered a remittance transfer provider if:

1. We process wires for our consumer customers whereby they might send a few hundred dollars to a relative's account in another country, or
2. We process IAT ACHs from our customer's accounts, through PAYPAL, to what look like foreign accounts. The origination and destination currencies are indicated as USD.
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#1657068 - 01/27/12 03:47 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
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1. Yes, unless all those remittances are under $15
2. Yes, if you accept the instructions from your customer to make those payments. No, if the transaction is authorized at PayPal and PayPal initiates the transfer.
Last edited by John Burnett; 01/27/12 03:49 PM.
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#1657082 - 01/27/12 03:58 PM Re: CFPB final Reg E remittance transfers John Burnett
Doug Hendrickson Offline
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Thanks John. I'll re-check the PayPal IATs. I don't believe we accepted instructions from our customer, but rather Payal initiated the transfer; but I'll double-check.
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#1658062 - 01/30/12 09:32 PM Re: CFPB final Reg E remittance transfers John Burnett
Southern gal Offline
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Should we start preparing for this now if it's not effective until Jan 2013?

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#1658153 - 01/31/12 01:32 AM Re: CFPB final Reg E remittance transfers Southern gal
rlcarey Online
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Galveston, TX
Originally Posted By: Southern gal
Should we start preparing for this now if it's not effective until Jan 2013?


Well, some people will probably wait until Dec. 31st, but I probably would not recommend that approach.
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#1658162 - 01/31/12 02:55 AM Re: CFPB final Reg E remittance transfers ahou
Kathleen O. Blanchard Offline

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And I agree....the earlier you start the more time you have to gain a full understanding of the requirements and what you will have to do to comply.
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#1658189 - 01/31/12 01:27 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
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Here's the latest -- The Final Rule will be published in the FR on February 7, and it will be effective 2/7/2013. The proposal to carve out some exemptions and clarify application to remittances requested in advance will be published the same day, with a comment period of 60 days (which would end on April 7, a Saturday). I'll be offering a BOL LearningConnect webinar on the remittance transfer rule on July 18, 2012 (it has not yet been added to the LearningConnect calendar).
Last edited by John Burnett; 01/31/12 01:29 PM.
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#1658229 - 01/31/12 02:31 PM Re: CFPB final Reg E remittance transfers John Burnett
Southern gal Offline
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TN
Thanks to each of you for your comments. I do plan to start work on this way before effective date.

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#1658996 - 02/01/12 03:18 PM Re: CFPB final Reg E remittance transfers Southern gal
RBanker Offline
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Austin Texas
Once again proving the value of a banking collaborative effort - I love what I can learn on BOL.

Let me clarify - perhaps I don't love what I learn, but I love that I can learn it here. eek
Last edited by R Banker; 02/01/12 03:19 PM.
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#1659166 - 02/01/12 05:33 PM Re: CFPB final Reg E remittance transfers ahou
EmilyAnn Offline
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Thank you John! I'll keep an eye out for the webinar.

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#1677130 - 03/13/12 09:18 PM Re: CFPB final Reg E remittance transfers ahou
gonetobeach Offline
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gonetobeach
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near Dallas
I am in the process of writing a summary on this and would like affirmation that this amendment only applies to remittance transfers (and all they entail) sent from someone here to a designated recipient (someone there).

All the disclosure, error resolution and cancellation provisions of Subpart B do not apply to a wire sent to someone inside the states? All this consumer protection only goes if the transfer is going outside the U.S.?

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#1677133 - 03/13/12 09:19 PM Re: CFPB final Reg E remittance transfers ahou
gonetobeach Offline
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gonetobeach
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near Dallas
Bumfuzzled!!

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#1677494 - 03/14/12 04:48 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
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Cape Cod
That's right. If the transfer is ordered for pickup/delivery outside the U.S. and territories, Subpart B applies.
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