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.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8