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#1869716 - 11/08/13 03:14 PM Subject to rule 10/28/13-how long to comply
Libby M. Offline
Platinum Poster
Joined: Sep 2007
Posts: 604
Mississippi, USA
I am trying to get this straight - we are a financial institution and as of 10/28/13 we had already exceeded 100 remittance transfers for the year 2013. Do we have six months to comply beginning 1/1/14 or do we have six months to comply beginning 10/28/13 or should we have been complying since 10/28/13?
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Lela Purvis, CRCM/CCBCO/CBAP


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Remittance Transfer Rule
#1869725 - 11/08/13 03:28 PM Re: Subject to rule 10/28/13-how long to comply Libby M.
zitch70 Offline
Gold Star
Joined: Apr 2001
Posts: 331
Edinburg, Texas
complying since 10-28-13. did you do more than 100 in 2012?

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#1869727 - 11/08/13 03:32 PM Re: Subject to rule 10/28/13-how long to comply zitch70
Libby M. Offline
Platinum Poster
Joined: Sep 2007
Posts: 604
Mississippi, USA
No
_________________________
Lela Purvis, CRCM/CCBCO/CBAP


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#1869739 - 11/08/13 03:53 PM Re: Subject to rule 10/28/13-how long to comply Libby M.
zitch70 Offline
Gold Star
Joined: Apr 2001
Posts: 331
Edinburg, Texas
must comply 6 months after 1-1-14 since you have fewer than 100 in 2012 and more than 100 in 2013. See 1005.30(f)(2)(ii)

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#1869742 - 11/08/13 03:57 PM Re: Subject to rule 10/28/13-how long to comply zitch70
Libby M. Offline
Platinum Poster
Joined: Sep 2007
Posts: 604
Mississippi, USA
That's what I thought but wanted verification! Thanks so much blush
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Lela Purvis, CRCM/CCBCO/CBAP


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#1870224 - 11/12/13 04:17 PM Re: Subject to rule 10/28/13-how long to comply Libby M.
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Lela,

To be technically correct, your six month "grace" would expire 6 months from the date you sent the 101st covered transfer in 2013, not 6 months from 1/1/14.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1919011 - 04/30/14 05:57 PM Re: Subject to rule 10/28/13-how long to comply John Burnett
river girl Offline
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Joined: Nov 2004
Posts: 1,005
If we aren't going to be ready within 6 months of sending the 101st wire, what are the penalties if we continue to send wires (without the new disclosures) until we are ready?

We are probably going to do a temporary halt until our vendor can be set up but management wants to include the penalty for non-compliance in their analysis.

I looked for penalties and am not having any luck.

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#1919046 - 04/30/14 06:32 PM Re: Subject to rule 10/28/13-how long to comply Libby M.
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I cringe when I see questions to the effect of "What's the worst they could do to us?"

Given that this rule was made final exactly one year ago today, I don't understand how a vendor can tell you with a straight face that it won't be ready with a 6-month grace period after you hit your 101st transfer. It's probably time for a "produce or else" discussion with the vendor.

As for a definitive answer on the penalties, I don't know.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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