If you are referring to remittance transfers for regulation E purposes, you only count international transfers that you originate on behalf of consumers. If you permit consumer customers to originate international bill payments or IATs, they count toward your 100 for your safe harbor. IATs that you receive as an RDFI are not remittance transfers since you did not originate them.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com