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#2237261 - 05/27/20 04:10 PM Estimated exchange rates and fees
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
If the exchange rate or fees are estimates, do the disclosures to the sender have to explicitly state that the exchange rate is an estimate, or the fees are an estimate?

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Remittance Transfer Rule
#2237418 - 06/01/20 03:54 PM Re: Estimated exchange rates and fees Bville
Diane Dean Offline
Member
Joined: Oct 2012
Posts: 92
Yes - in looking at §1005.31(d) and the commentary, it requires that estimates be accompanied by the term "Estimated" or something similar:

(d) Estimates. Estimated disclosures may be provided to the extent permitted by § 1005.32. Estimated disclosures must be described using the term "Estimated" or a substantially similar term in close proximity to the estimated term or terms.

Commentary:
1. Terms. A remittance transfer provider may provide estimates of the amounts required by § 1005.31(b), to the extent permitted by § 1005.32. An estimate must be described using the term "Estimated" or a substantially similar term in close proximity to the term or terms described. For example, a remittance transfer provider could describe an estimated disclosure as "Estimated Transfer Amount," "Other Estimated Fees and Taxes," or "Total to Recipient (Est.)."

The model forms also give some examples.
_________________________
Diane Dean
http://www.bankerscompliance.com

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#2237463 - 06/02/20 02:34 PM Re: Estimated exchange rates and fees Bville
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
Thank you!

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