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BankersOnline.com Forums Dodd-Frank Final Rules Discussions Remittance Transfer Rule In person remittance transfer and disclosures
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#1865046 - 10/25/13 03:20 PM In person remittance transfer and disclosures
dlcooper Offline
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Joined: Aug 2011
Posts: 10
We are trying to determine if anyone sees a problem with this practice. Our Wire department will be the only department that will have access to complete the remittance transfer disclosures. If the consumer comes to the Bank to request a foreign wire and they don't want to wait for the disclosure but opts to give us a phone number to receive the disclosures verbally what kinds of problems are we setting ourselves up for? I don't see anything in the Reg that doesn't permit this practice. Thanks!

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Remittance Transfer Rule
#1865149 - 10/25/13 05:48 PM Re: In person remittance transfer and disclosures dlcooper
CrookedVulture Offline
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Joined: Jul 2008
Posts: 148
Originally Posted By: Island Girl
We are trying to determine if anyone sees a problem with this practice. Our Wire department will be the only department that will have access to complete the remittance transfer disclosures. If the consumer comes to the Bank to request a foreign wire and they don't want to wait for the disclosure but opts to give us a phone number to receive the disclosures verbally what kinds of problems are we setting ourselves up for? I don't see anything in the Reg that doesn't permit this practice. Thanks!


I don't think that's going to fly. 1005.31(a)(3)(i) says that disclosures can be given orally over the telephone if the transaction is conducted orally and entirely by telephone. The transaction you're referring to is done in person and wouldn't qualify, in my opinion.

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#1865434 - 10/28/13 03:06 PM Re: In person remittance transfer and disclosures dlcooper
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I agree. What you COULD do, although it would not be a particularly customer-service-oriented practice, is have the customer place the order directly with the wire department over the telephone, perhaps with the branch vetting the customer's identification.

That will only work, of course, with transfers ordered by a bank depositor whose account will be used to fund the transfer, because the receipt can be given my mail.
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