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#1751480 - 10/23/12 04:42 PM Reg. E Remittance and debit card transactions
ilovebulldogs! Offline
Platinum Poster
Joined: Sep 2007
Posts: 555
Mississippi, USA
At a recent banking association meeting the presenter stated that if our consumer customer uses his debit card to purchase an item from an overseas company, the transaction would be considered a remittance transfer. I am not sure the presenter was correct and would like clarification.

Is the following statement accurate?

If our consumer customer uses his debit card to purchase something from an overseas company for personal, family or household purposes, that transaction would not be a remittance transfer even though the funds for payment of the transaction came out of our customer's account, in a state, the originator of the transaction was the overseas company and not our bank.

Whew! Please advise smile

Last edited by John Burnett; 10/24/12 11:25 AM.

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eBanking / Technology
#1751486 - 10/23/12 04:49 PM Re: Reg. E Remittance and ACH [Re: Wonderofitall]
Andy_Z Offline
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Joined: Oct 2000
Posts: 26,984
On the Net
I don't see this as subject to the Reg E, part B rules because the payment is through the card network.

John has a webinar coming up on this topic so we'll see if he'll give us a taste of what he'll discuss. I suspect this would be one of his topics.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1751551 - 10/23/12 06:37 PM Re: Reg. E Remittance and ACH [Re: Wonderofitall]
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 38,448
Cape Cod
I'm doing a reprise of my May webinar on the Remittance Transfers rule on Friday, October 26, to include the latest developments (the addition of the "safe harbor" exception and changes regarding remittance transfers requested in advance of their transfer dates -- including preauthorized transfers). I'll cover this sort of question, too.

Here's a link to webinar information:

As for your question, Wonderofitall, a consumer's debit card transaction is not a remittance transfer under this rule because he or she is not making a request directly of his/her bank to complete the transfer. Instead, the transfer is being initiated by the merchant (or ATM deployer) at the consumer's request.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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Moderated by:  Andy_Z