The Final Rule will increase the threshold for determining coverage from 100 to 500. If you sent more than 100 remittance transfers in the previous (2019) or current calendar year (2020), you are subject to the rule today. As of July 21, 2020, you will be subject to the rule if you sent more than 500 remittance transfers in the previous or to-date in the current calendar year.
In case you have forgotten how this works, if you exceed the threshold in the prior year, you are subject to the rule for the entire next year. If you did not exceed the threshold in the prior year but exceed it at any point during the current year, you’re required to comply within six months of exceeding the threshold.
The Rule will also allow for the use of an estimated exchange rate, as well as, estimated third-party fees, when certain conditions are met. Other technical corrections were also made. If these changes impact you, stay tuned! We will be bringing you things to consider in the June issue of our magazine, Banking on BCC.
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Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!