In the proposal for required documenation, given to consumers when providing them with international wire services, a financial institution who had less than 25 consumer international wires per year was exempt. Was this changed to 100? If so where can I find it in the reg./rule?

Yes, it was changed to 100 in the final rule , which was released yesterday.

§1005.30(f)(2)(i)(A)&(B)

I have been studying the commentary. Commentary should help, but has confused me. Please help me understand the 100 safe harbor.

I am not seeing where the 100 or fewer remittance transfers states international wires. Does the 100 count for all remittance transfers sent out in the previous calendar year and current calendar year?
Thanks

See below! It is not clear.

Thank you!

"When the final remittance rule was released, the Bureau also published a Notice of Proposed Rulemaking seeking comment on whether to provide additional safe harbors and flexibility in applying that final rule in certain situations. The Bureau has now received those comments and has finalized the supplementary rule, which will also take effect on Feb. 7, 2013.

The Bureau concluded that those institutions that consistently conduct 100 or fewer remittance transfers per year do not provide transfers in the “normal course of business” and therefore are not subject to the new requirements. However, if a company that provided 100 or fewer remittance transfers in the previous year provides more than 100 remittance transfers in the current year, the rule provides a reasonable transition period to come into compliance."

Look at this thread, it seems to indicate 100 foreign items...

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1714543&page=2

Great, thanks for the link to the thread. I had not found that one yet and it seems to clear up quite a bit.