We have a funds transfer request that will be sent from a US individual to an account in NYC to an intermediary bank and then the final destination will be to a trust acct beneficiary in another country.

Will we still have to give Reg E disclosures for this?

Please let me know if you need more info from me.

Thank You

Is the beneficiary the designated recipient?

"Designated recipient" means any person specified by the sender as the authorized recipient of a remittance transfer to be received at a location in a foreign country.

As per the funds transfer, the final beneficiary is in another country.

I was told that our transfer will be sent to a US account to another US Bank and our original transfer will not leave the US.

However, the beneficiary is located outside the US.

Then I do not understand. You are either using an intermediary bank to the send a foreign wire transfer for you, in which case, yes you owe them a disclosure, or you are wiring the money to an account of the beneficiary at the NYC bank and you just know that it is eventually going to be wired over seas.

I am told we are not using an intermediary bank to send the transfer. It will go directly to US bank, where the beneficiary of the transfer has their account.

The funds are not going to be wired outside of the US.

Then it is not a foreign remittance transfer under subpart B of Regulation E.