For banks that are intending to undertake this, if you initiate a covered transaction and the consumer alleges an "error" how does your bank expect to research and resolve the issue? I'm not looking for an explanation of the regulation, only a sketch of what your investigatory efforts would be; e.g. are you expecting to turn the problem over to your intermediary bank, contact the beneficiary bank in Kuala Lampur, Brussels or Riyadh?

What's the plan?

We have a reg E dept that takes care of reg E notices of error. They will also, do these, no changes in procedures.

Notice of error received by branch, teller, operations center, call center, etc will forward the notice to that dept.

We do over 250 exchanges or transfers per month. We have not had any problems to date. So we do not anticipate any errors when this is effective.

Thank you. Does anyone else have some thoughts on what they intend to do here?

Ken,
I had really hoped the resolution process for error could be turned over to the intermediary bank. However, ours hasn't even developed a process for receipts yet.

Is it possible to look to the intermediary bank to handle that process?

The intermediary bank may well be part of your process, but if you're the bank the consumer/sender dealt with, you're the provider, and you're responsible for the error resolution process.

John,
Since we will not have access to anything other than the initial request, how will we be expected to conduct the investigation? How are other banks planning to do this?

Hence, the initial post... The banks I've spoken with are focused on getting the information for the disclosures. From my perspective, that's the least of the problems involved.

The issue I'm trying to raise is not how banks are going to get the exchange rate they quote, but what it is they are going to do when it turns out the exchange rate was incorrect and the recipient receives less than disclosed. (I'm aware that estimates can be used initially.)

We use the SPOTs system. When a customer orders an exchange of currency the rate quote is locked for that transaction. The exchange of currency will be completed within the day.

Consumers usually is transferring dollars from their account to their peso account in Mexico. Our consumers are wealthy and moving tens of thousand dollars at a time. We do not have the consumers moving a hundred dollars. Our fee is too high for the small consumer.