This question is related to outgoing foreign wires in USDollars initiated by our bank on behalf of our consumer customer where the beneficiary bank and beneficiary is located in another country such as Taiwan or Thailand for example. Under the new wire remittance rule it is understood our bank would have to provide required disclosures including expected fees, amounts, and charged including the expected amounts to be received on the other side, error resolution, etc. However, what if the receiving bank upon receiving our USD wires automatically converts to their foreign currency from USD (such as New Taiwan Dollar (NTD) of other currency)? Does our bank have to know the NTD dollar amount dispersed to the beneficiary in Taiwan and the exchange rate and does this information need to be disclosed in the initial disclosures provided to our customer upon initiation? If so, I am wondering how we will know, and how will our customer's know which beneficiaries maintain USD accounts with the foreign bank and which do not? Can anyone provide clarification??

Extracted from Comment 31(b)(1)(iv)-1:

"If a provider does not have specific knowledge regarding the currency in which the funds will be received, the provider may rely on a sender's representation as to the currency in which funds will be received for purposes of determining whether an exchange rate is applied to the transfer. For example, if a sender requests that a remittance transfer be deposited into an account in U.S. dollars, the provider need not disclose an exchange rate, even if the account is actually denominated in Mexican pesos and the funds are converted prior to deposit into the account. If a sender does not know the currency in which funds will be received, the provider may assume that the currency in which funds will be received is the currency in which the remittance transfer is funded."

If the sender requests that the transfer be deposited to the recipient's account in dollars, you can assume that the transfer will be completed in dollars. But if the sender asks for the transfer to be completed in the currency of the country in which the recipient (or the recipient's account) is located, you must disclose the exchange rate and the converted amount expected to be received. If the sender doesn't know, you may assume the recipient will receive U.S. dollars if that's the currency that funded the transfer.

Thank you John, this definitely is what I am looking for. I appreciate your doing the research and posting. I'll refer further to the commentary.

Thanks again!!

And I'll say a short prayer, BruwinLady, that all of your customers are in the "Gee, I don't know!" category so you can avoid using an exchange rate.

Not that any of my other prayers on Dodd-Frank have worked, you understand ....

Hello banking colleagues, I thought I'd add to this question since it is in the same realm.

The models allow a dollar to dollar example, yet states within the requirements that we are to calculate into the foreign amount.

It appears that our vendor is setting up a dollar to dollar only version for our use. Not sure if we can "require" that transfers be made in US dollars, even though it is a model disclosure.

I was just digging in, and while some was straight forward, this section and the estimates made me pause.............Thanks for any input. Iwill keeping reading these threads as I absorb more through round two of reading.

You can limit your service to $US transfers only, but that will restrict the number of countries to which you can offer transfers, and may also make your services less attractive than those of a competitor.

Thank you John. I feel very dumb in asking this, but is there a list of countries that will accept transfers in US dollars? I understand that there was to be a list to help us with taxes, etc., but have no purused nor am I certain that this is what you are referring to.

Our correspondent can likely send in any currency (except those restricted under OFAC, etc.). We only do about 25 applicable transfers a month, and I hate the thought of potential evasion. Our wire vendor was not going to be able to assist us in compliance, but thanks to the timing change, has come up with an automated solution. I will have to investigate if they can disclose in recipienct currency. Smaller community banks have more challenges with some of these regulations, and we may have to consider making this a manual process. Thanks again for your time.

You have hinted at the source you need to contact for the information. It's your correspondent or wire vendor. I am not aware of a list that's publicly accessible.

Remember that if the sender directs you to send U.S. dollars, you can do that, and you won't be responsible if the recipient institution converts the remittance amount into a local currency before crediting it to the designated recipient. Also, if your sender doesn't know whether the funds can be received in dollars and doesn't instruct you to convert them, you can denominate the transfer in dollars.

Music to my ears - thank you.

How would that practice restrict the number of countries to which you can ofrer transfers?

There are, I believe, some restrictions on sending US dollars abroad.

Reg E RTR restrictions? Or from another source?

There may not be legal constraints involved. But it's conceivable that a recipient's bank isn't able to convert U.S. dollars to locally denominated funds.

John, I understand that the rule allows us to rely on whether or not the customer knows the foreign currency in which the transfer is to be made but from what you are saying here it also sounds like we are permitted to state that a transfer will only be in USD? We have a situation where our vendor does not yet "support" a particular foreign currency. If our vendor does not support a currency, are we permitted to send in USD? I'm just not finding that as permissible in the rule - not yet, anyway. Can you point me in the direction where you got the info? Thanks much!

If you are constrained to U.S. dollars, explain that fact to the Sender. If that's acceptable, you can proceed. If it's not acceptable, you can't accept the business.

Thanks John.