Skip to content
BOL Conferences
Learn More - Click Here!

Page 1 of 2 1 2
Thread Options
#1654226 - 01/23/12 03:11 PM CFPB final Reg E remittance transfers
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
Ugh. I've been dreading the day CFPB would implement this rule.
_________________________
Opinions are my own and not of my employer.

Return to Top
Operations Compliance
#1654325 - 01/23/12 04:44 PM Re: CFPB final Reg E remittance transfers ahou
gonetobeach Offline
100 Club
gonetobeach
Joined: May 2004
Posts: 132
near Dallas
Me too! And am I correct in thinking this applies to us all....not just 10B and above?

Return to Top
#1654330 - 01/23/12 04:47 PM Re: CFPB final Reg E remittance transfers gonetobeach
mtngrrl Offline
Gold Star
mtngrrl
Joined: Mar 2011
Posts: 499
Northern California
Originally Posted By: gonetobeach
Me too! And am I correct in thinking this applies to us all....not just 10B and above?


Yeah, but don't feel bad. It also applies to non-FI money transmitters. They're looking at a safe harbor for institutions/organizations that only do a few per year (proposed at 25 transfers in the last year). Otherwise, we're all in it together!
_________________________
Be kind; everyone you meet is fighting a hard battle.
--all opinions are my own--

Return to Top
#1654402 - 01/23/12 05:43 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
They do sneak up on you!. I found a news release on this, but haven't yet received a notice. Thanks for the heads up!
Last edited by John Burnett; 01/23/12 05:46 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1654528 - 01/23/12 07:38 PM Re: CFPB final Reg E remittance transfers John Burnett
LFTbanker Offline
100 Club
Joined: Dec 2008
Posts: 137
So will this be effective one year from today's publication? Or is it one year from the original publication? Does anyone know for sure?

Return to Top
#1654569 - 01/23/12 08:05 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
One year from when it gets published in the Fed Register, which should be in a couple/few days.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1654582 - 01/23/12 08:24 PM Re: CFPB final Reg E remittance transfers ahou
Aggs Offline
Diamond Poster
Aggs
Joined: Nov 2009
Posts: 1,331
Hoosier Country
Link to summary:
http://www.consumerfinance.gov/regulations/final-remittance-rule-amendment-regulation-e/

Link to final rule in the Federal Register:
http://www.consumerfinance.gov/assets/do...2020%202012.pdf

Just FYI. I already had to get the links for my supervisor, so I thought I'd share here. grin
_________________________
CRCM + CAMS = certified compliance nerd

Opinions expressed in these threads are my own and not my employer's.

Return to Top
#1654608 - 01/23/12 08:25 PM Re: CFPB final Reg E remittance transfers John Burnett
LFTbanker Offline
100 Club
Joined: Dec 2008
Posts: 137
Thanks so much. That is how I should have said it and what I was hoping and thinking would be the case.

Return to Top
#1654722 - 01/23/12 11:23 PM Re: CFPB final Reg E remittance transfers ahou
EmilyAnn Offline
Gold Star
Joined: Jul 2007
Posts: 273
Does anyone know if BOL will be holding a webinar on the new foreign remittance rule? I looked at the Learning Connect calendar for the next few months, but didn't see anything. Maybe something will be in the works now that the rule has been finalized???

Also, I was reviewing the model notices in the final rule with our Operations Officer. We agreed that we would likely need to develop a fill-in form for the pre-transaction disclosure and receipt. We don't have an automated solution for developing these kinds of disclosures (and thankfully, we don't have a lot of volume in this area).

In any case, is anyone aware of an automated solution? Or whether the forms vendors or teller platforms might tackle it? We haven't heard anything from them, but will certainly be checking with our vendors.

Return to Top
#1654744 - 01/24/12 12:43 AM Re: CFPB final Reg E remittance transfers ahou
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Nothing scheduled yet that I know of. How many bankers are that interested in a 2 hour webinar?
Last edited by Andy Z; 01/24/12 12:44 AM.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#1654857 - 01/24/12 02:34 PM Re: CFPB final Reg E remittance transfers EmilyAnn
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If you use a vendor in this line of business, you should ensure that the vendor is aware of the new requirements and that they will be effective a year from now. Then start pushing for regular progress reports on updating the vendor software, forms, etc., to meet the January deadline.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1655147 - 01/24/12 07:23 PM Re: CFPB final Reg E remittance transfers Andy_Z
EmilyAnn Offline
Gold Star
Joined: Jul 2007
Posts: 273
Originally Posted By: Andy Z
Nothing scheduled yet that I know of. How many bankers are that interested in a 2 hour webinar?


For the record, we would definitely be interested. We're familiar with Reg E of course, but now that it's been expanded to include this previously uncovered area, we'd love some expert guidance.

Return to Top
#1656398 - 01/26/12 04:17 PM Re: CFPB final Reg E remittance transfers ahou
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Do I understand correctly that we would be considered a remittance transfer provider if:

1. We process wires for our consumer customers whereby they might send a few hundred dollars to a relative's account in another country, or
2. We process IAT ACHs from our customer's accounts, through PAYPAL, to what look like foreign accounts. The origination and destination currencies are indicated as USD.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

Return to Top
#1657068 - 01/27/12 03:47 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
1. Yes, unless all those remittances are under $15
2. Yes, if you accept the instructions from your customer to make those payments. No, if the transaction is authorized at PayPal and PayPal initiates the transfer.
Last edited by John Burnett; 01/27/12 03:49 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1657082 - 01/27/12 03:58 PM Re: CFPB final Reg E remittance transfers John Burnett
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Thanks John. I'll re-check the PayPal IATs. I don't believe we accepted instructions from our customer, but rather Payal initiated the transfer; but I'll double-check.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

Return to Top
#1658062 - 01/30/12 09:32 PM Re: CFPB final Reg E remittance transfers John Burnett
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
Should we start preparing for this now if it's not effective until Jan 2013?

Return to Top
#1658153 - 01/31/12 01:32 AM Re: CFPB final Reg E remittance transfers Southern gal
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Originally Posted By: Southern gal
Should we start preparing for this now if it's not effective until Jan 2013?


Well, some people will probably wait until Dec. 31st, but I probably would not recommend that approach.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1658162 - 01/31/12 02:55 AM Re: CFPB final Reg E remittance transfers ahou
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
And I agree....the earlier you start the more time you have to gain a full understanding of the requirements and what you will have to do to comply.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1658189 - 01/31/12 01:27 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Here's the latest -- The Final Rule will be published in the FR on February 7, and it will be effective 2/7/2013. The proposal to carve out some exemptions and clarify application to remittances requested in advance will be published the same day, with a comment period of 60 days (which would end on April 7, a Saturday). I'll be offering a BOL LearningConnect webinar on the remittance transfer rule on July 18, 2012 (it has not yet been added to the LearningConnect calendar).
Last edited by John Burnett; 01/31/12 01:29 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1658229 - 01/31/12 02:31 PM Re: CFPB final Reg E remittance transfers John Burnett
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
Thanks to each of you for your comments. I do plan to start work on this way before effective date.

Return to Top
#1658996 - 02/01/12 03:18 PM Re: CFPB final Reg E remittance transfers Southern gal
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Once again proving the value of a banking collaborative effort - I love what I can learn on BOL.

Let me clarify - perhaps I don't love what I learn, but I love that I can learn it here. eek
Last edited by R Banker; 02/01/12 03:19 PM.
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

Return to Top
#1659166 - 02/01/12 05:33 PM Re: CFPB final Reg E remittance transfers ahou
EmilyAnn Offline
Gold Star
Joined: Jul 2007
Posts: 273
Thank you John! I'll keep an eye out for the webinar.

Return to Top
#1677130 - 03/13/12 09:18 PM Re: CFPB final Reg E remittance transfers ahou
gonetobeach Offline
100 Club
gonetobeach
Joined: May 2004
Posts: 132
near Dallas
I am in the process of writing a summary on this and would like affirmation that this amendment only applies to remittance transfers (and all they entail) sent from someone here to a designated recipient (someone there).

All the disclosure, error resolution and cancellation provisions of Subpart B do not apply to a wire sent to someone inside the states? All this consumer protection only goes if the transfer is going outside the U.S.?

Return to Top
#1677133 - 03/13/12 09:19 PM Re: CFPB final Reg E remittance transfers ahou
gonetobeach Offline
100 Club
gonetobeach
Joined: May 2004
Posts: 132
near Dallas
Bumfuzzled!!

Return to Top
#1677494 - 03/14/12 04:48 PM Re: CFPB final Reg E remittance transfers ahou
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
That's right. If the transfer is ordered for pickup/delivery outside the U.S. and territories, Subpart B applies.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
Page 1 of 2 1 2

Moderator:  Andy_Z, John Burnett