The October 28, 2013 implementation date for International Remittance rules has come and gone! Financial institutions either decided to continue business as usual, well with disclosures if they were over 100 transaction threshold, or not to do those types of transactions at all. The rules led us to believe that if you were under the magic number of 100 the institutions still needed to track to see if and when the threshold was reached for the disclosure requirements. No one ever said anything about tracking transactions if the institution was over the threshold. If you haven’t heard, the Federal Financial Institutions Examination Council (FFIEC) has recently approved revisions to the Call Reports of those institutions with over 100 International Remittance transactions.
Effective March 31, 2014 there will be a question pertaining to International Remittance transactions on the Call Report. The question is whether or not the institution has created over 100 International transactions. If the institution has over 100 transactions, an estimate as to the number of transactions and dollar value is required. Before your 2013 information is sent to the great information dungeon, tally up the International Remittance transactions for the report.
Something to keep in mind as you progress through 2014, if your institution happens to be over $1 billion in assets, effective March 31, 2015, the institution must also report the income in the total services charges on deposit accounts, including those for International Remittances.
Tracking is now the new normal for International Remittances, Safe Harbor or Not!
I am providing a link to FIL 3-2014 if you want to read the good news for yourself.
https://www.fdic.gov/news/news/financial/2014/fil14003.html