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#1749643 - 10/16/12 07:00 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Joined: Mar 2011
Posts: 78
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#1749649 - 10/16/12 07:08 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Power Poster
Joined: May 2002
Posts: 6,259
NW IL
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#1749730 - 10/16/12 09:28 PM
Re: Remittance Transfer Rule-Intl. Wires
Cornfed Turtle
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100 Club
Joined: Jul 2008
Posts: 148
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Did I hear correctly that they are either excluding or are considering excluding programs such as Directo a Mexico from the remittance transfer requirements?
Also, it was somewhat encouraging to hear that the error rules regarding senders who've given the provider incorrect information (e.g. incorrect account number) may be revised or are at a minimum going to get a second look.
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#1749739 - 10/16/12 09:43 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Gold Star
Joined: Apr 2001
Posts: 331
Edinburg, Texas
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We have decided to stop doing RMTs begining next year. We do over 100 per month. The risk is too great unless they change the error when providers have given incorrect information. One wire where we have to refund will wipe out all income received.
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#1749901 - 10/17/12 04:17 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Platinum Poster
Joined: Dec 2008
Posts: 731
Tennessee
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I need to make sure I explain this correctly to Mgmt....At the rate we are going we will be close to the 100 mark for this year....
If we decide that we are no longer going to offer this service BUT do hit 101 this year, we will not be able to ANY RMT in 2013 unless we comply with the reg....even if we only do a few in 2013 to accommodate some of our customers....we would have to comply with the reg for those few.....because we did 101 in 2012...
Then if we don't do any in 2013....we could accommodate some of customers in 2014....
Is that correct?
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#1750139 - 10/18/12 03:06 AM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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If you hit 101 in 2012 you will have to comply with the rule for any subpart B transfers you handle starting on 2/7/13, and counting any that you do for ALL of 2013 toward the 100 level for 2013. If you count 100 or fewer in 2013, the safe harbor rule would theoretically get you off the hook for 2014 until you hit 101 for that year, and then a 6 month grace period on compliance would apply. But the Bureau has said that it will be watching for providers trying to "game the system" to avoid having to comply.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1750182 - 10/18/12 01:17 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Junior Member
Joined: May 2012
Posts: 33
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I also found that to be odd. They won't interpret their own rules. We actually chuckled over that. So if you use their manual for compliance and the Feds have a problem you can't rely on the information for basis of you policy and procedures?
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#1750224 - 10/18/12 02:05 PM
Re: Remittance Transfer Rule-Intl. Wires
Kathleen O. Blanchard
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Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
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We invited them in-house to specifically help us with a troublesome reg. We worked together on examples of how to interpret the reg and they still spent two slides telling us it wasn't an interpretation of the Fed. And none of our examples were memorialized in slides either. It was good training, but certainly couldn't be used to take on the next EIC.
Overall, I liked the CFPB webinar though.
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#1750279 - 10/18/12 03:25 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Diamond Poster
Joined: Jan 2010
Posts: 1,028
Utopia
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We just received a notice from our wire transmiter and I'm confused about something in there. It states "consider converting the wires first to the beneficiary's local currency" I'm not sure how that is supposed to help?
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#1750282 - 10/18/12 03:30 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Junior Member
Joined: May 2002
Posts: 46
On the banks of the Rio Grande
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You'll have the exchange rate that you need for the disclosure.
And you will have more control over the transaction, making your disclosures more accurate and limiting your exposure to loss under the dispute resolution portion (when the amount received isn't what you disclosed).
Last edited by ejommen; 10/18/12 03:41 PM.
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#1750362 - 10/18/12 05:22 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Power Poster
Joined: Oct 2009
Posts: 3,927
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We also are exempted due to the 'de minimis' of 100 transactions.
I've sent a memo to senior management advising them of that fact and will incorporate a 'blurb' in the monthly compliance report to the Board. In addition, I'll add an annual procedure at year-end to calculate the number of 'remittance transfers' done for the year to see if the status has changed. I don't believe a formal policy is necessary.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1750373 - 10/18/12 05:32 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Power Poster
Joined: Nov 2004
Posts: 6,842
Illinois
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One thing to consider, Doug is that the 6-month clock for required compliance starts ticking immediately upon reaching the 100 threshold during the year. If there is a sudden increase in your remittance transfers and you reach 100 in May 2013, but don't realize it until December 2013, you will have been put of compliance between November 2013 and the time that you are able to begin complying with the requirements. For that reason, I'm going to be calculating my remittance transfer total at least quarterly.
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#1750375 - 10/18/12 05:38 PM
Re: Remittance Transfer Rule-Intl. Wires
BrianC
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Power Poster
Joined: Oct 2009
Posts: 3,927
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Good point! It might be best to schedule mine quarterly or semi-annually just to keep on top of it.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1750378 - 10/18/12 05:42 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Platinum Poster
Joined: Apr 2005
Posts: 639
Out there
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One solution to this mess might be to have any of your clients that do send frequent transfers to the same people, open an account at your bank with that person as co-owner, and provide the person overseas a debit, ATM or check access to the account. Since the account would be located in teh US, wouldn't that remove the transfers from the rules?
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#1750953 - 10/19/12 09:02 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Power Poster
Joined: Nov 2004
Posts: 6,842
Illinois
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Those would not be remittance transfers, ture. I'm going to remove my Reg E hat and put on my BSA hat...
How do we want to go about gathering CIP information for the foreign individual, monitor the account, etc.? I think I'll stick to counting transfers. Lower risk IMHO.
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#1751161 - 10/22/12 06:54 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Platinum Poster
Joined: Apr 2005
Posts: 639
Out there
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I agree that you would probably not want to handle all situations like this, but it does seem like there could be situations, especially in cases of well known clients (e.g. a student studying broad, a private banking client's mother living overseas) where this could be sold as helping the customer reduce fees, and reduce the number of transfers to "count", especially until the detials of this regulation are figured out.
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#1751397 - 10/23/12 02:22 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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I like the use of a debit card tied back to a U.S. account on which the individual overseas is a joint owner or authorized cardholder because that individual may find that it's not convenient to set up a local bank account, and may not always know where he or she will be traveling. The cost is certainly manageable (a local ATM fee and the exchange rate) and there's no need to arrange for individual transfers. The individual overseas would have to have reasonable spending habits before I'd want to be the one replenishing the account, of course, but ...
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1751653 - 10/23/12 09:50 PM
Re: Remittance Transfer Rule-Intl. Wires
Kay
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Platinum Poster
Joined: Nov 2007
Posts: 767
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Can you limit remittance transfer services to persons with existing accounts that are in good standing and have been open at least one year?
Can you offer only in person transfers?
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Comments are strictly my own and not that of my employer.
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