Disclosures via phone

read the reg, section 1005-31(a)(3). Checked all the disclosures in (b)(i) to (b) (viii). Do we need also to give the error resolution languarge (180 dayes, etc. etc.)?

Yes you have to provided the transaction is conducted orally by phone. The section that requires the error resolution be provided orally with the pre payment disclosure is found under the receipt disclosure information 1005.31(b)(2)(iv). Since you probably will be mailing the receipt a day after or up to 30 days after it is best to provide the error resolution with the pre payment disclosure also.

The timing of your oral disclosure of the cancellation provision is affected by .31(a)(3)(iii), which adds it to the things you have to orally include in the pre-payment disclosure. The error resolution disclosure can stay on the receipt.

Thanks

we have the error resolution on the script for the phone transfers and on the receipt mailed to the sender.

We are revisiting our remittance transfer processes. For wire transaction conducted by telephone, can we send the combined disclosure in place of the receipt if we orally provided the pre payment disclosure?

If you are complying with the special oral disclosure requirements for telephone-conducted remittance transfer requests in section 1005.31(a), you can send the (b)(2) disclosure in accordance with the (e)(2) timing requirements. The (b)(2) disclosures include evidence of the sender's payment for the service.

The combined disclosure includes all the (b)(2) disclosures except for the evidence of payment, which has to be provided.

So my question back to you is, what benefit do you anticipate by sending a combined disclosure?

We are looking at changing our process and our vendor does not appear to have a receipt available that we can use. I am trying to explore options based on with what we have at this time.

Your vendor isn't able to give you what you need to comply with the rule? I'll spare you my customary reply to that kind of news.

You could take the combined disclosure, which is essentially the receipt without the annotation showing the payment was received, and add receipt info to it. What info? The word "paid" and a date and time would do the trick. If you have a transaction tracking or ID number, that should also be added. Then arrange for delivery.