We provide ACH IAT consumer transfers to our customers and I have included these in calculating the < 100 exemption rule. We have around 92 ACH IAT outbound transfers (all to Mexico) per month and minimal consumer to consumer wire activity (less than 25 per year).
We process these transactions through FED Global ACH that an exemption is in place and that we may not need to concern ourselves with the disclosures.
Does anyone have any documentation that would confimr this for me?