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Washington
CUNA seeks comment on Fed remittance disclosures
WASHINGTON (5/23/11)--The Credit Union National Association (CUNA) has encouraged credit unions to comment on a Federal Reserve proposal that would require institutions to add new disclosures to remittance transfers that are sent to foreign countries. The Fed proposal would apply to virtually all cross-border, consumer-initiated electronic funds transfers – other than debit or credit cards, transactions from a consumer’s U.S. credit union account to a credit union or bank account in that consumer’s name in another country, or online bill payments made through a website. International wire transfers, international ACH transfers, and products such as the World Council of Credit Unions (WOCCU) IRnet, as well as money transfer organizations such as Western Union and Vigo, would be subject to the rule. However, international wire transfers that are initiated from accounts at federally insured credit unions would be exempt from many of the cost estimate requirements until at least 2015. Credit union international wire and ACH transfers would not be exempted from some of the error resolution and cancellation requirements. There are additional proposed exemptions for transfers between a sender’s account in the U.S. and an account in the sender’s name in another country, as well as a proposed exemption for institutions that do not regularly engage in international transfers. The proposed disclosures are required by the Dodd-Frank Act. One disclosure would be provided before the remittance transaction is initiated. A second disclosure would need to be provided when the remittance is received. The initial disclosure would include the actual exchange rate, fees and taxes, and the amount of currency to be received by the recipient, although, as noted above, federally insured credit unions would be able to provide an estimate of the costs rather than the exact costs. The second disclosure would come in the form of a written receipt that includes that same prepayment disclosure as well as additional information about error resolution, provider and regulator contact information, and the availability of the funds upon receipt. For the CUNA comment call, use the resource link.


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