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#1654226 - 01/23/12 03:11 PM
CFPB final Reg E remittance transfers
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Power Poster
Joined: Aug 2002
Posts: 3,094
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Ugh. I've been dreading the day CFPB would implement this rule.
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#1654330 - 01/23/12 04:47 PM
Re: CFPB final Reg E remittance transfers
gonetobeach
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Gold Star
Joined: Mar 2011
Posts: 499
Northern California
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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!
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Be kind; everyone you meet is fighting a hard battle. --all opinions are my own--
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#1654402 - 01/23/12 05:43 PM
Re: CFPB final Reg E remittance transfers
ahou
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1654528 - 01/23/12 07:38 PM
Re: CFPB final Reg E remittance transfers
John Burnett
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100 Club
Joined: Dec 2008
Posts: 137
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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?
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#1654569 - 01/23/12 08:05 PM
Re: CFPB final Reg E remittance transfers
ahou
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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One year from when it gets published in the Fed Register, which should be in a couple/few days.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1654608 - 01/23/12 08:25 PM
Re: CFPB final Reg E remittance transfers
John Burnett
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100 Club
Joined: Dec 2008
Posts: 137
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Thanks so much. That is how I should have said it and what I was hoping and thinking would be the case.
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#1654722 - 01/23/12 11:23 PM
Re: CFPB final Reg E remittance transfers
ahou
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Gold Star
Joined: Jul 2007
Posts: 273
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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.
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#1654744 - 01/24/12 12:43 AM
Re: CFPB final Reg E remittance transfers
ahou
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10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
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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.
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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
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#1654857 - 01/24/12 02:34 PM
Re: CFPB final Reg E remittance transfers
EmilyAnn
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1655147 - 01/24/12 07:23 PM
Re: CFPB final Reg E remittance transfers
Andy_Z
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Gold Star
Joined: Jul 2007
Posts: 273
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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.
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#1656398 - 01/26/12 04:17 PM
Re: CFPB final Reg E remittance transfers
ahou
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Power Poster
Joined: Oct 2009
Posts: 3,927
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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.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1657068 - 01/27/12 03:47 PM
Re: CFPB final Reg E remittance transfers
ahou
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1657082 - 01/27/12 03:58 PM
Re: CFPB final Reg E remittance transfers
John Burnett
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Power Poster
Joined: Oct 2009
Posts: 3,927
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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.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1658062 - 01/30/12 09:32 PM
Re: CFPB final Reg E remittance transfers
John Burnett
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Platinum Poster
Joined: Mar 2008
Posts: 504
TN
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Should we start preparing for this now if it's not effective until Jan 2013?
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#1658153 - 01/31/12 01:32 AM
Re: CFPB final Reg E remittance transfers
Southern gal
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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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.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1658189 - 01/31/12 01:27 PM
Re: CFPB final Reg E remittance transfers
ahou
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1658229 - 01/31/12 02:31 PM
Re: CFPB final Reg E remittance transfers
John Burnett
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Platinum Poster
Joined: Mar 2008
Posts: 504
TN
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Thanks to each of you for your comments. I do plan to start work on this way before effective date.
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#1658996 - 02/01/12 03:18 PM
Re: CFPB final Reg E remittance transfers
Southern gal
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Power Poster
Joined: Jul 2003
Posts: 2,675
Austin Texas
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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.
Last edited by R Banker; 02/01/12 03:19 PM.
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My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.
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#1659166 - 02/01/12 05:33 PM
Re: CFPB final Reg E remittance transfers
ahou
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Gold Star
Joined: Jul 2007
Posts: 273
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Thank you John! I'll keep an eye out for the webinar.
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#1677494 - 03/14/12 04:48 PM
Re: CFPB final Reg E remittance transfers
ahou
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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That's right. If the transfer is ordered for pickup/delivery outside the U.S. and territories, Subpart B applies.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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