The Consumer Financial Protection Bureau (CFPB) released version 2 of
its Small Entity Compliance Guide for International Fund Transfers on August 8, 2013. The revisions detail
changes made to the remittance Rule earlier this year, including the error
resolution liabilities when the sender provides an incorrect account number or
recipient institution identifier, a provision I think it’s safe to say we are
all very happy was changed.
Also, the revised guide provides
the updated amendment that, under certain circumstances, disclosure
requirements regarding fees charged by a recipient’s bank and taxes charged by
a person other than the remittance transfer provider, may be optional. Essentially, fees and taxes of which an
institution has no knowledge, control over or that vary extremely, such as some
countries taxes on Wires.
In addition to the
revised guide, the CFPB released a You-Tube Video that provides an overview of
the Final Rule, including the recent changes.
On a related note, the
CFPB published a Clarificatory Amendment and technical correction
to the Final Rule on August
14, 2013. The amendment details available remedies for certain errors that
might occur, and clarifies the language of a few areas of the Final Rule. No comments are requested.
The technical correction corrects
a numbering error; the CFPB inadvertently deleted a section; this amendment
adds that section back in and corrects the numbering issue.
October 28, 2013, is the date by which remittance
transfer providers must be in compliance with the 2013 remittance transfer Rule,
including the clarifying amendments and technical correction.