The new remittance rule requires the bank to give the consumer specific disclosures, can these be given over the phone if they call into our call center to do a wire? The call would be recorded and they would ask for confirmation that they understand what was read. I would think the answer is no, that we would need to provide a disclosure they could keep. Just want to confirm.

See Reg E 1005.31

Oral notice is permitted provided that you state the required items that must be disclosed, and that the conversation takes place in the customer's primary language. If you have customers whose primary language is something other than English who will be making oral wire transfer requests, you will need to have people in your call center who make state the disclosures in the appropriate language.

Even when you are able to make disclosures orally, it only applies to the pre-purchase disclosure. If you conduct the entire transaction over the telephone, you still have to provide the written receipt required by 1005.31(b)(2) or 1005(b)(3), although can mail it or deliver it within one business day after payment is made (or in limited cases, in or with the next periodic statement or within 30 days if the payment is made from an account in your bank.

Shameless self-promotion alert: We'll review this and other requirements under the Foreign Remittance Transfer rule tomorrow in my BOL Learning Connect webinar: "Foreign Remittance Transfers: The 'Final' Word."