I am now confused with thenconcept of gettinh the customer's consent to do the transaction. Does this "consent" apply to remittances scheduled in advance or to all remittance transfer requests? When I spoke with the CFPB ealier today they begen discussing the need for the consumer to censent, and that many banks will be getting signed consent, especially because CFPB regulated banks may be getting the feeling the CFPB thinks it would be good practice. Can anyone clarify situations when we would need a formal "consent"?

If the customer is requesting the wire, we provide a prepaymentdisclosure and receipt or combined disclosure, and they have. 30 minute cancellation, am I missing a formal "consent" step?
Definitely losing it!

Consider the sequence of disclosures. The prepayment disclosure and its timing are designed to inform the consumer of the cost of completing the requested transaction. It's similar to when you go into a shop and ask the shop-keeper the price of a piece of merchandise. You don't decide whether to buy the merchandise until you know the price. Your customer doesn't give you the "go-ahead" to complete a transfer until after he knows how much it will cost to send that $100 to Tante Marie in Guadeloupé. The consumer's consent occurs when he or she agrees to the cost and pays for (or gives you authorization to charge his/her account for) the transfer. That consent doesn't have to be documented, according to the regulation, and it is certainly implied by the sequence of events in the provider's procedures.

Evidence of the consent might be a signed debit/credit card sales slip; a faxed-back page with payment instructions and a checked box indicating agreement to the costs and terms; the exchange of cash for which a receipt is given, etc. The regulations does not specify that consent must be documented or suggest the form of consent. The requirement for a prepayment disclosure (or combined disclosure) and its timing prior to payment simply imply that consent is involved.