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#1855440 - 09/25/13 07:15 PM Compliance date for new rule effective 10/28/13
cgdiamond Offline
Member
Joined: Oct 2012
Posts: 97
NY
The new Reg E becomes effective on 10/28/2013.

Our vendor hinted that they might not be able to hit the target. There might be about two weeks of delay.

Is there any grace period to be compliant with the rule?

If not, what may be the consequences of non-compliance as of 10/28/2013?
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Remittance Transfer Rule
#1855470 - 09/25/13 07:47 PM Re: Compliance date for new rule effective 10/28/13 cgdiamond
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
No grace period is contemplated.

Consequences? You either have to suspend your remittance transfer business until the vendor gets its act together or you risk penalties like negative exams, perhaps an enforcement action of some type.

I suggest you start lighting a fire under the vendor. Do you have performance standard penalties in your contract, and would they be available if the vendor misses the compliance deadline? It's not like vendors haven't had plenty of notice this little rule was coming, after all.
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