Hello All, I need Help please.

We are moving our foreign wires to the front line. The front line will create the combined disclosure and the customer will sign it. It is sent to back office who will review for errors and then forward to our vendor to process. Once the vendor gets the disclosure, the funds are electronically pulled from the customers account.
My question is in regards to the Proof of Payment. We are required to send the proof of payment when the payment is made which is after the customer has left.
If you use combined disclosures, how are you meeting this proof of payment requirement?

Payment is made when the customer pays you (cash, check, credit card) or when payment is authorized. Comment 31(e)-2.

Your depositor authorizes the payment with his/her signature. That's when payment is made.

When the customer signs the combined disclosure with our front line staff agreeing to the amount and authorization to draft the account, that is meeting the proof of payment requirement. At that point, would our front line associate stamp the combined disclosure paid and provide a copy to the customer?
Our concern is if for some reason that wire did not go out and what our liability would be.

I have a follow up question to the one above. We are stamping our combined disclosures with a paid stamp that payment was made at example, 12:00. Payment will not be drafted until, at most, a few hours later. Are we still in compliance with such a large time gap?

Your proof of payment stamp needs to reflect the time and date of payment, and payment includes an authorization to charge an on-us account (as discussed above). If the transfer doesn't take place, you aren't entitled to the fees or any other part of the charge to the account. The regulation doesn't address damages for not following through. But I can envision a case in which a Sender tries to sue you for not completing a transfer you charged him for, with the result that he suffered some kind of monetary loss.

If the debit to the account doesn't hit for a few hours, you could find yourself trying to overdraw an account if there's been a debit that's snuck in before you (think an ATM withdrawal or POS transaction, or maybe a check payable to a third party who came in to cash it). For those reasons, I recommend placing a hold on the account for the amount of the charge, to be released when the debit is processed.

If the wire is delayed, there could be a currency conversion rate change that will force you to pay more than you have the authorization to collect from the account. Or the delay could result in late arrival of the funds, which can cost the service provider (your bank) a penalty.