Topic: International Remittance Transfers
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We have a business customer that would like to use our online banking ACH origination system to make payments to businesses located in India. Currently, the customer pays these businesses by wire transfer. Is there a way for us to originate ACH transactions to India? Does the FedGlobal ACH system offer ACH origination to India?
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No, we do not believe that your bank would be able to originate ACH transactions to India. The Federal Reserve’s FedGlobal ACH system allows banks to originate ACH transactions to several countries outside of the U.S., most of them located in Europe, but its services do not extend to India. To originate ACH payments outside…
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Do we qualify for the safe harbor exemption from the Regulation E international remittance transfer rules? Our customers receive more than one hundred international ACH transactions (IATs) every year; do those transactions disqualify us? These IATs typically are Paypal transactions, and we are the receiving financial institution.
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No, we do not believe that IATs received by your bank would disqualify your bank from the safe harbor exemption in Regulation E. The Regulation E remittance transfer rules exempt entities that provided one hundred or fewer remittance transfers in the previous and current calendar year. A remittance transfer is one “requested by a sender…
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Are we required to provide customers with a copy of the wire confirmation receipt that we receive after an outgoing wire is sent through Fedwire?
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We are not aware of any law or rule that would require you to provide a copy of the actual wire confirmation. You should, of course, check your account agreements, which may require you to provide the receipt or some other notification for outgoing wires. Regulation J, which governs funds transfers through FedWire, does not impose…
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We did over a hundred international wires last year, but only about five of those were for consumers — the rest were for businesses. Can we still qualify for the safe harbor from the CFPB’s new international remittance rules?
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We believe that an institution sending only five international transfers for consumers per year could qualify for the safe harbor in the CFPB’s new international remittance rules. Because “remittance transfer” is defined as an international transfer requested by a “sender,” and “sender” is defined as a consumer making the transfer for personal, family, or household…