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#1728296 - 08/07/12 08:02 PM
Re: International Money Transfers
Al Miller
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Thanks, Al, for the heads up. Someone was asking about this this morning.
Thanks to your early notice, I've managed to updated the BOL Alphabet Soup version of the regulation with all the changes.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1728299 - 08/07/12 08:07 PM
Re: International Money Transfers
Al Miller
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Power Poster
Joined: Aug 2002
Posts: 3,094
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Thanks Al and John. You're so efficient and much appreciated.
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Opinions are my own and not of my employer.
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#1728511 - 08/08/12 02:16 PM
Re: International Money Transfers
Al Miller
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Platinum Poster
Joined: Mar 2008
Posts: 808
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so the de minimus means banks with fewer than 100 wires will be exempt from the rule?
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#1728525 - 08/08/12 02:28 PM
Re: International Money Transfers
Al Miller
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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The de minimis (note spelling) provision will mean that a bank with 100 or fewer remittance transfers of all types (wires, IATs, qualifying bill payments, etc.) in 2012 and 100 or fewer in 2013 will not be subject to subpart B requirements. If, in 2013 (or any subsequent year), it conducts the 101st remittance transfer for that year, it becomes subject to the rule, but has a 6-month compliance grace period. So, for example, if your bank does 100 or fewer remittance transfers in 2012, and conducts its 101st remittance transfer for 2013 on August 1, 2013, it will have until February 1, 2014, to begin complying (assuming it continues to be a remittance transfer provider).
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1728554 - 08/08/12 03:00 PM
Re: International Money Transfers
Al Miller
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Junior Member
Joined: May 2012
Posts: 33
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Does the de minimis only count consumer wires, or do we include wires for business purpose in that count as well. I know all types of wires but Reg E is a consumer Reg. Most of our wire activity is business related, but if we count those we do more then 100 wire transfer per year. I appriciate anyone's opinion.
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#1728558 - 08/08/12 03:04 PM
Re: International Money Transfers
Al Miller
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Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
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This is pretty mind-boggling to me. How can a bank be expected to disclose the fees that intermediary banks in the payment chain will deduct from the wire amount and also the exchange rate applied by the beneficiary's bank?
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#1728566 - 08/08/12 03:10 PM
Re: International Money Transfers
devsfan
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100 Club
Joined: Jul 2008
Posts: 148
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This is pretty mind-boggling to me. How can a bank be expected to disclose the fees that intermediary banks in the payment chain will deduct from the wire amount and also the exchange rate applied by the beneficiary's bank? They can't be, and yet, the rule exists.
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#1728569 - 08/08/12 03:13 PM
Re: International Money Transfers
Al Miller
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Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
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So how are we all going to comply, and how will that change our fees?
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#1728579 - 08/08/12 03:27 PM
Re: International Money Transfers
devsfan
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100 Club
Joined: Jul 2008
Posts: 148
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So how are we all going to comply, and how will that change our fees? That's the million dollar question.
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#1728609 - 08/08/12 03:52 PM
Re: International Money Transfers
Al Miller
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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The ABA has asked Congress to delay the effective date for two more years for many of the reasons noted in this thread. We'll see if they have any success. Even with the temporary estimate provision, it's gonna be a bear.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1728630 - 08/08/12 04:12 PM
Re: International Money Transfers
Al Miller
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Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
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Congress hasn't done anything useful in quite some time so we should not expect any relief, but it would be nice since I should be retired by then.
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#1728851 - 08/08/12 06:54 PM
Re: International Money Transfers
Al Miller
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Power Poster
Joined: Nov 2001
Posts: 7,988
FINALLY ABOVE the gnat line
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What public policy issue was being addressed/solved by this regulation?
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My Opinion Only.
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#1729601 - 08/10/12 02:05 PM
Re: International Money Transfers
Al Miller
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Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
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As Jennawer was wondering - I too am trying to figure out if the 100 applies to consumer transactions as Reg E is a consumer reg or do we count our business activity?
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#1729615 - 08/10/12 02:22 PM
Re: International Money Transfers
Jerseygirl
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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The disclosures (and thus the threshold count) would only apply to consumer transactions.
Complaining here is understandable, but ineffective. Either write to the Pollyanna Agency (CFPB), discontinue the service, or contact Western Union about being an agent.
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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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#1729641 - 08/10/12 02:47 PM
Re: International Money Transfers
John Burnett
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Diamond Poster
Joined: Oct 2002
Posts: 1,027
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The de minimis (note spelling) provision will mean that a bank with 100 or fewer remittance transfers of all types (wires, IATs, qualifying bill payments, etc.) in 2012 and 100 or fewer in 2013 will not be subject to subpart B requirements. Is this meaning 100 or fewer foreign wires or 100 wires, etc. no matter where they went? We only had 1 foreign wire last year.
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#1729650 - 08/10/12 02:52 PM
Re: International Money Transfers
Kathleen O. Blanchard
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Note the quote...not just wires.
Epiphany: Every bank will need to count all the little puppies to prove it does not apply. Examiners with nothing else to write about will say they should have compliance procedures in place in case they do cross the threshold.
Big fun!
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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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#1729819 - 08/10/12 06:37 PM
Re: International Money Transfers
Al Miller
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Gold Star
Joined: Nov 2000
Posts: 489
KY
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Note: you have six months to be in compliance once you cross that threshhold.
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Opinion expressed are my own and not necessarily those of my employer.
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#1729823 - 08/10/12 06:40 PM
Re: International Money Transfers
Elwood P. Dowd
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Diamond Poster
Joined: Oct 2002
Posts: 1,027
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OK, still checking. We only did 1 foreign wire, our core processor says they don't do bill pay outside the US so I think I'm down to finding out about foreign ACH, right?
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#1729832 - 08/10/12 06:57 PM
Re: International Money Transfers
Al Miller
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Yup, and it's only outbound IATs that you'll have to look for. If you don't allow your customers do make them....
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1729861 - 08/10/12 07:41 PM
Re: International Money Transfers
John Burnett
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Diamond Poster
Joined: Oct 2002
Posts: 1,027
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OK the question came up concerning Paypal. Our customer buys something from someone in Japan and pays through paypal. Since the money is going from us to paypal and then they send it on does that actually count as us sending it out of the country?
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#1729919 - 08/10/12 09:56 PM
Re: International Money Transfers
Al Miller
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Power Poster
Joined: Nov 2004
Posts: 6,840
Illinois
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In those instances, Paypal is the originator, and it's bank the ODFI. As the RDFI, these transactions would not count towards your 100.
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#1730014 - 08/13/12 12:38 PM
Re: International Money Transfers
Al Miller
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Start by asking yourself whom did your customer ask/authorize to move the funds? In this case, it's PayPal, so your bank is not the remittance transfer provider.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1730498 - 08/14/12 12:42 PM
Re: International Money Transfers
Al Miller
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Gold Star
Joined: Apr 2001
Posts: 331
Edinburg, Texas
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Does Paypal have to comply with this mess? If not then why not direct all our consumers to use Paypal or Western Union for their foreign transfers.
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