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Amendment to Reg Foreign Remittance Transfers

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Question: 
In regards to the final rule on the amendment to Reg E - Foreign Remittance Transfers, I am wondering how you interpret the official staff commentary on how to determine the number of remittance transfers provided in order to fall under the remittance transfer provider safe harbor of sending 100 or less remittance transfers in a year (1005.30(f)(2)(ii)). More specifically, do remittance transfers requested by business senders count in the 100 transfers? For example, if our bank sends 140 total remittance transfers per year, but only 80 of the transfers are requested by consumer senders (the other 60 were requested by business senders), does our bank only have 80 qualifying remittance transfers, thereby qualifying us for the safe harbor in which we would not have to adhere to the disclosure requirements of this rule?
Answer: 

When determining whether your institution falls under the safe harbor provision (100 or fewer remittance transfers), you count only those transactions on which you would have to provide disclosures, etc., (1) if the rule had been in effect during the full year and (2) there was no safe harbor provision. You arrive at this result by following the trail of definitions of each of the regulation's terms, starting with "remittance transfer."

Short version: You only count qualifying transfers.

First published on BankersOnline.com 1/14/13.

First published on 01/14/2013

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