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#1776738 - 01/16/13 02:39 PM Foreign Remittance Transfers
malavm Offline
Member
Joined: May 2009
Posts: 50
We are working to ensure we can meet the new requirements. We are planning to utilize the Temporary Exception to estimate the exchange rate, fees and total credit to the beneficiary. In reading the documentation I have, it does not state that the credit date can be estimated. Can anyone veryify for me that the credit date can be estimated? This is a sticking point for us.
Thanks!

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Remittance Transfer Rule
#1777353 - 01/17/13 04:28 PM Re: Foreign Remittance Transfers malavm
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
No, it can't be guessed at. At least, you cannot say that's what you're doing. Whatever date you put on the receipt is the date by which the funds must be credited to the recipient's account or be capable of being retrieved by the recipient.

Best advice is to eliminate as must risk as possible and push the date out as far as you think is necessary to create really good odds that the funds will be available by that date, and add the wording to say that they may be available sooner.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1777356 - 01/17/13 04:30 PM Re: Foreign Remittance Transfers malavm
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
But don't be ridiculous with this. You can't just say you're always going to use a date that's a month in the future, because that would be an obvious effort to circumvent the regulation.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1777491 - 01/17/13 06:49 PM Re: Foreign Remittance Transfers malavm
malavm Offline
Member
Joined: May 2009
Posts: 50
Understood. Thank you very much!

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