News & Announcements

Regulation E Update: Remittance Transfers

Posted on November 27, 2012

The Consumer Financial Protection Bureau (CFPB) has issued a final rule on “remittance transfers” disclosures and compliance requirements under Regulation E, as required by the Dodd‐Frank Wall Street Reform and Consumer Protection Act (Dodd‐Frank Act), effective on February 7, 2013.

More specifically, the final rule applies to credit unions and financial institutions that provide consumers with international electronic funds transfer services, because it broadly defines the term “remittance transfers” to include virtually all cross‐border electronic funds transfers initiated by consumers in the U.S., including international ACH, international wire transfers, and products such as WOCCU’s IRnet. The final rule also applies to money transfer organizations (MTOs), such as Western Union or Moneygram. The final rule does not apply to most transfers involving credit, debit, and prepaid cards.

GENERAL BACKGROUND
The final rule on “remittance transfer” generally requires a remittance transfer provider, such as a credit union, to provide a consumer sender:
1. “Prepayment Disclosure” ‐ A written disclosure provided prior to the initiating a transaction that includes the actual exchange rate, fees and taxes, and the amount of currency to be received by the recipient; and
2. A written receipt when payment is authorized or made for the transfer that includes the pre‐payment disclosure, information about error resolution, provider and regulator contact information, and the availability of the funds upon receipt.
3. The final rule also specifies error resolution rights, standards for resolving errors and recordkeeping rules, and cancellation and refund policies for all remittance transfers, including those with an estimated exchange rate, such as those falling within the partial exemption for FICU’s; and lastly
4. A consumer sender may cancel a remittance transfer within 30 minutes from payment and will receive a full refund, including all fees.
For further details, please refer to the final rule and model forms in the FEDERAL REGISTER.

ACTION REQUIRED
Corporate America is working with Western Union Business Solutions to migrate our members to a new platform (GPA) to ensure compliance with the regulation. It is our intention to have this
conversion completed by December 10. Western Union will be hosting webinars in order to provide training on the new GPA platform. The webinar will be approximately one and a half
(1.5) hours in duration and will cover the following topics:
• A general walk‐though of the system
• An outline of some of the key differences in systems
• A demonstration of several types of transactions
• Q&A period

In order to accommodate as many schedules as possible there will be three different opportunities to attend this webinar live. This webinar will also be recorded and linked to Corporate America's website. In order to register, please click on the link below to the webinar you would like to attend.

December 3, 2012 at 10am EST/7am PST
December 5, 2012 at 1pm EST/10am PST
December 7, 2012 at 4pm EST/1pm PST

Please contact your CACU Consultant or email the Compliance Department at compliance@corpam.org if you have any questions or concerns.

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