I am not seeing guidance in the Rule on how are we to handle requests received after the designated cut off time which would include weekends and holidays. In these instances the wire would not be sent until the following business day and the exchange rate may have changed overnight or over the weekend. Must the exchange rate be locked at the time of the request or is it permissable to use estimates?

Your ability to use estimates is pretty restricted, and you don't get any release based solely on the fact the transfer is arranged (requested, disclosed and paid for) fewer than five days in advance. And don't forget that you have to have the ability to cancel the transaction within 30 minutes of payment if it's schedule less than three days in advance, too. So the only logical response I can make is that you don't accept requests outside your business hours. And maybe not in the last 30 minutes of each business day, either.

Since this continues to be an active question I wanted to run by you our thoughts on this. Thanks for your emails on this topic. We also spoke with the CFPB.
We receive wire requests after the cutoff time and also on Saturdays. Since, as I understand it, we cannot provide estimated disclosures in this scenario, we will be instructing the customer to contacts us on the next business day. [in accordance with the CFPB instructions] [It could also be that the branch contacts the customr on the next business day, customer service] We would then provide the combined disclosure and process the request on that business day.

We are thinking that we would take the wire information and properly identify the customer - but then would tell the customer to come back the next day or call the customer the next day and then provide the oral disclosures for the early and mail out the receipt.

Do you think this would work?

I am struggling with the same issue that the original poster had. The Commentary to Section 1005.31(e) states that for the purposes of the regulation, "payment is made, for example, when a sender provides cash to the remittance transfer provider or when payment is authorized."

So does this mean if on Saturday a customer authorizes a wire to be sent on Monday that payment was made on Saturday (even though there will be no debit to the customer's account until Monday)?

Another interesting thing is that according to Section 1005.31(f) the required disclosures need to be accurate when "payment is made." So again, does this mean that on Saturday we can provide the appropriate exchange rate information knowing that it is likely to change by Monday when the wire is sent and still be compliant?

If this is true, that means we can accept wire transfer requests after our cut-off time without dealing with the customer inconvenience of turning folks away until the next business day. We would ensure that we allow at least 30 minutes for cancellation.

Thoughts??