Our Bank is working on compliance issues related to the new Intl. Remittance Transfer rule under Regulation E.

We are wondering what other banks are doing as it relates to international consumer wire transfers and concern over the risks related to claims of errors and required error resolution.

Are banks limiting the dollar amount of international wires; increasing the intl. wire fee; or just not offering them anymore?

Your response is appreciated.

We are still discussing our options. On the table,

1. not offering anymore - we don't do that many of them
2. partnering with a large international bank to do them
3. partnering with Western Union

We will most likely partner with someone.

We have decided not to continue the service to our 35 consumers who used the service in the first four months of the year. There is no reasonable way for us to comply with the disclosures and the error resolution is way too scary.

Are the majority of banks deciding to forego international consumer wires after February 2013?

We haven't considered that yet. However, we do very few of them, so I'll be monitoring them for the rest of the year to see if we fly under the limits.

I don't believe they have established a minimum limit yet, have they?

I'll check. For some reason a half dozen or a dozen or so was sticking in my head.

25 in the Proposed Rule, which came out at the same time as the Final Rule. So I take it they haven't made a Final decision on that yet.

The original proposed number was 25, I've not heard anything one way or the other since.

Yea, I hadn't thought so.

We run in the 45-60 range annually. ugh...

It is still undecided. Industry groups proposed much higher than 25 and got a no way response so perhaps a tad higher will be the final number.

We're thinking of stop offering int'l wires for consumer customers. QUESTION: For those of you considering "partnering" with a big bank to do these, how would that work? Wouldn't you still be required to do all those disclosures to your customer? Also, wouldn't you still be on the hook if the customer decides to complain after the fact about a wire they didn't give you correct information for? I mean this is Reg E we're talking about and I don't think you can delegate your responsibilities?
Thoughts??? Thanks.

I'm confused today: do the rules apply to a wire sent to a foreign country in US dollars to be received in US dollars (no conversion) - and what we call "international" wire transfer at our bank (as opposed to the "foreign" wire in which there is a US dollar conversion). In looking at the definition for remittance transfer in the reg it doesn't sepearate out US dollar/US dollar transfers - so that's probably my answer right there.

Regardless of what you call it, the Reg applies to any wire transfer for a consumer that begins in the US and ends in a foreign country regardless of what currency in which the wire was sent/received.

There are still "seats" available for my July 18 webinar on this regulation. The beauty of webinars is that the "meeting room" is expandable and we can always set up more "seats." The more the merrier!

We've decided to stop consumer wires (approx 30% of our volume) - we cannot risk the error resolution piece. We'll continue with processing international wires for our business customers. Plan now is to decide what, when and how to communicate this to our affected consumers.

So, if we are using a correspondent bank, these rules do not apply?

Not true. If you are the consumer's point of contact for requesting the transfer and the funds are going overseas electronically, you'll be subject to the rules.

Thanks.

Has anyone heard anything on the minimum number yet? Are they waiting for a midnight deadline???

Bureau has not yet issued a final rule on that question.

Just out.... they raised the threshold to 100 or fewer per year!

http://www.consumerfinance.gov/pressrele...l-institutions/

Ooh, JJ you be safe.

We've already updated Reg E in Alphabet Soup to reflect the changes.

If I'm not missing something, isn't the 100 threshold just this side of worthless?

Definition from 1005.30(e):
"A “remittance transfer” means the electronic transfer of funds requested by a sender to a designated recipient that is sent by a remittance transfer provider."

There is nothing in the definition about "international" transfers. So all domestic ACH, bill pay, and wire transfers would be included in the 100 count. I can't imagine there are too many banks, small or not, that have less than 100 ACH, bill pay, and wire transfers annually. Thus they would not be able to claim exemption from this rule under the 100 count provision.