My question is whether a proof of payment required if we choose to use a combined disclosure? 1005.31(b)(3) states "If a sender initiating a remittance transfer receives a combined disclosure provided under § 1005.31(b)(3) and then completes the transaction, the remittance transfer provider must provide the sender with proof of payment." From my perspective the sender completes the transaction when he signs and authorizes our wire form. The process we follow is we have the sender complete the wire form. We then provide a combined disclosure with the proof of payment included. The wire is scanned to our wire room who enters it into our wire system and funds are deducted from the account. He never physically pays for it since the funds are already in the account.

Your perspective is valuable, but the Bureau has a different one. You complete the combined disclosure, which you have to provide before the customer pays for the transfer. Then you ADD an annotation (it could be as simple as a PAID stamp) to show that he's paid for the transfer, making it a true receipt.

And the regulation says that the in-house customer who is paying from is account with you pays at the time he gives you the OK to charge his account, regardless of the time at which you pull the funds.

Resurrecting this one please! Similar question here...so is it permissible for us to provide a combined disclosure with a paid stamp allowing the customer to leave when we might not actually debit the account or send the wire until later that same day?

That's correct. The time of payment is when the Sender tenders payment in cash or by check, credit or debit card, or gives the remittance transfer providing bank authorization to charge the Sender's on-us account. That's when you provide the paid stamp on the combined disclosure you gave the Sender as a disclosure BEFORE payment.