Compliance 504:
Because the "safe harbor" is available only if you have 100 or fewer remittance transfers in both the previous year and in the current year, it would not help you, at least not during 2013. On 2/7/13, when the rule becomes effective, you'd be ineligible for the safe harbor exemption if you exceeded 100 in 2012. So, unless you can demonstrate that you do not provide remittance transfer services in the normal course of business (using the "facts and circumstances" test, which has never been defined), you'll have to comply during 2013.
If you manage to stay at or under 100 for 2013, you should qualify for the safe harbor exemption starting on 1/1/2014, unless you hit 101 transactions in 2014, at which time you'd start a 6-month transition period.
Last edited by John Burnett; 11/07/12 03:26 PM.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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