Your bank receives the instruction and money from the consumer to wire out the funds. You have to deliver the disclosures.
I've been reading 1005.30(a) and 1005.35, hoping for a loophole. Is there any way for a bank to act as an agent for its upstream correspondent, shifting liability to them? What if a bank simply takes the wire info from the customer, and transmits it to the correspondent bank by fax or secure email? Who then is the remittance transfer provider?
(I'm also wondering why a correspondent bank would want to accept the risk that their agent will mess up the deal, if the liability is on the remittance transfer provider.)
And regarding Ahou's comment: I agree the agent would have to deliver the disclosure, but could the burden for preparing it be shifted upstream?