As you probably recall, the Remittance Transfer Rule in Regulation E (Electronic Funds Transfer), went into effect on October 28, 2013. The types of transactions covered under the rule were expanded, some of which, have been covered under the Bank Secrecy Act (BSA). This overlap caused certain transactions to fall outside the BSA definitions of “funds transfer” [§ 1010.100(w)] and “transmittal of funds” [§1010.100(ddd)].
To avoid these transactions falling outside the grasp of the BSA, FinCEN recently issued a final rule to revise these definitions. Specifically, the following verbiage was added to each definition:
Electronic fund transfers as defined in section 903(7) of the Electronic Fund Transfer Act [15 U.S.C. 1693a(7)], as well as any other funds transfers that are made through an automated clearinghouse, an automated teller machine, or a point-of-sale system, are excluded from this definition.
The final rule is effective January 3, 2014.
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!