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Remittance Transfer Rule-Under 100 International

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Question: 
The remittance Transfer Rule becomes effective on 10-28-13 and if our bank does less than 100 international wires in a year, would we be covered under the safe harbor of this ruling?
Answer: 

It's really not possible to give you a very good answer with the limited information you've provided.

"International wires" and "remittance transfers" are not equivalent terms. Some outbound international wire transfers will qualify as remittance transfers; some will not. And there are other types of transactions that fit the definition of remittance transfer.

You need to start by determining all of the types of electronic transfer of funds transactions that your institution does, including bill payment transactions, wire transfers, ACH transactions, etc., for individuals (whether or not they are your depositors) for consumer purposes. Then determine which of those meets the definition of remittance transfer under subpart B of Regulation E. If, after culling out the transactions that don't meet the definition, you can count to see whether you have more than 100 for either your activity in 2012 or (thus far) for your activity in 2013. If you are over 100 for either year, the safe harbor exception will not apply to you for 2013; if you went over 100 in 2012 but don't go over 100 in 2013, you're in the safe harbor to start off 2014.

With the October 28 effective date already a couple of weeks behind us, I hope you were able to complete this analysis. If you can't document that you carefully counted your covered transactions for 2012 and 2013, you won't be able to successfully support the use of the safe harbor provision for an exemption from the rule.

First published on 11/11/2013

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