Question on how to fix this issue - Disclosures

Posted By: New Day

Question on how to fix this issue - Disclosures - 02/15/23 10:25 PM

I'm at a new bank and there are gaps in their international remittance transfer processes. They usw WF for the IRTs but they don't give the disclosures and receipt at the time the customer approves the wire. They have built a 30 minute stop in the system and the wire won't even go to WF until the 30 mins. are up. They have a remittance transfer form they have the customer fill out, but it is not compliant with all the required disclosures. Once the 30 mins. are up, the wire will be sent to WF and the disclosures will be sent to the bank. The wire department receives them and sends them to the banker to send to the customer. I thought maybe if they created a separate wire form with all the disclosure information that coiuld get by with it. Once the disclosures were received from WF they could still send them out.


anyone have any thoughts or comments?
Posted By: RockChucker, CAMS

Re: Question on how to fix this issue - Disclosures - 02/15/23 11:21 PM

Depending on the volume of wire activity, I believe the requirement to provide some of the disclosures for wires and the 30 minute window went away. Does that apply to your new institution?
Posted By: New Day

Re: Question on how to fix this issue - Disclosures - 02/16/23 10:12 PM

If you mean the change from 100 to 500 remittance transfers, it doesn't apply. They were close and chose to treat it as if the bank was required to comply.