Regulation E, Remittance Transfer Rule

Refer to the Federal Consumer Financial Protection Guide for additional guidance on reviewing Regulation E.

Questions to Consider

Does the credit union provide remittance transfers? If yes:

• Did the credit union provide 500 or fewer remittance transfer in the previous calendar year, and 500 or fewer remittance transfers in the current calendar year?
  • If so, then beginning on July 21, 2020, the credit union will be considered to have met the normal course of business safe harbor and will not be subject to the Remittance Transfer Rule.
• Does the credit union estimate the exchange rate and other disclosures that depend on the exchange rate (those include the amount that will transferred to the designated recipient disclosed in the currency that will be received, the amount of any covered third party fees disclosed in the current that will be received, and the amount the designated recipient will receive disclosed in the currency that will be received, after deducting the covered third party fees)? If yes, were the following conditions met?
  • The remittance transfer provider is an insured institution.
  • The insured institution cannot determine the exact exchange rate for the remittance transfer at the time it must provide applicable disclosures.
  • In the prior calendar year, the insured institution did not exceed the exception’s threshold with regard to the particular country to which it is sending the remittance transfer.
  • The remittance transfer is sent from the sender’s account with the insured institution.
• Does the credit union estimate the covered third-party fees and other disclosures that depend on the covered third-party fees? Is yes, were the following conditions met?
  • The remittance transfer provider is an insured institution.
  • The insured institution cannot determine the exact covered third-party fees required to be disclosed for the remittance transfer at the time it must provide applicable disclosures.
  • Either (a) the insured institution made 500 or fewer remittance transfers to the designated recipient’s institution in the prior calendar year, or (b) a United States federal statute or regulation prohibits the insured institution from being able to determine the exact covered third-party fees required to be disclosed for that remittance transfer.
  • The remittance transfer is sent from the sender’s account with the insured institution.

Last updated on September 15, 2021