Hello, I am looking for some clarification on disclosures required for reoccurring foreign remittance transfers. It should be noted that all funds required for foreign remittance transfers are always debited from the customer's account.

I know that for the initial transfer in the series we are required to provide the same disclosures as with a one time transfer (we provide a combined disclosure and also the proof of payment once payment is made). For the series of scheduled transfers, the reg states we can provide a disclosure with the future transfer dates, the cancellation rights as well as the providers phone number, website, etc..

If we provide a separate document with the initial combined disclosure that lists the dates of the future scheduled transfers, the disclosure and the bank information is that sufficient for the next 12 months (provided no changes occur that would require an updated disclosure)? AND do we also have to include the "date available" on the separate document, for each of the future scheduled transfers?

Any feedback would be greatly appreciated.