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Compliance Outlook. International Remittance Transfers. International Remittance Transfer. On October 28, 2013 the Consumer Financial Protection Bureau’s International Remittance Transfer rule takes effect. . International Remittance Transfer. Remittance transfers are –

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Compliance Outlook

International Remittance Transfers

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International Remittance Transfer

On October 28, 2013 the Consumer Financial Protection Bureau’s International Remittance Transfer rule takes effect.

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International Remittance Transfer

Remittance transfers are –

electronic transfers of funds that are more than $15; requested by a person in the United States, and sent to people or companies in foreign countries.

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International Remittance Transfer

  • Credit unions are exempt from the requirements if:
    • They provided 100 or fewer remittance transfers in the previous calendar year; and
    • They provide 100 or fewer remittance transfers in the current calendar year.
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International Remittance Transfer

  • Temporary Exceptions:
    • Applies to credit unions;
    • Credit Union may estimate the applicable exchange rate, back-end fees and taxes, and total funds to be received.
    • Exceptions are limited and temporary and will only be available for qualified transfers through July 21, 2015.
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International Remittance Transfer

  • Disclaimers:
    • Recipient may receive less due to fees charged by the recipient’s bank and foreign taxes.
    • You have the right to dispute errors in your transaction. If you think there is an error, contact us within 180 days at
    • 800-123-4567 or www.credit union.com. You can also contact us for a written explanation of your rights.
    • You can cancel for a full refund within 30 minutes of payment, unless the funds have been picked up or deposited.
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International Remittance Transfer

  • Disclosures:
    • Written
    • Oral
    • Mobile
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International Remittance Transfer

  • Error Provision Requirements:
    • The credit union has to demonstrate that the member provided an incorrect recipient institution identifier;
    • For institution identifier errors, the credit union has used reasonable means to verify the identifier;
    • The credit union gave the appropriate notice to the member;
    • The funds were deposited into the wrong account; and
    • The credit union used reasonable efforts to attempt to recover the funds.
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International Remittance Transfer

  • IRT Error:
    • An incorrect amount paid by a member in connection with the remittance transfer, such as being charged more than the total shown on the receipt;
    • A computational or bookkeeping error made by the provider relating to the remittance transfer, such as miscalculating the amount the recipient will receive;
    • Failure to make available to a designated recipient the amount of currency disclosed to the sender; and
    • Failure to make funds available by the disclosed date of availability (including the non-delivery of funds).
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International Remittance Transfer

  • IRT Error:
    • Credit Union must investigate the error and make a determination with 90 days;
    • within 3 business days of completing the investigation report the result of the investigation; and
    • if an error did occur correct the error within 1 business day, or as soon as reasonably practicable.
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Thank you for joining me for this review of the CFPB’s International Remittance Transfer Rules Stay Tuned…

Shawn Wolbert, CIA, CUCE

Director CU System Relations

101 S. Washington Square, Suite 900

Lansing, MI 48933-1703

(800) 262-6285 Ext. 486

(734) 658-5427 Mobile

Follow me on Twitter – Shawn Wolbert @ Go2CUGuru