The CFPB recently issued FAQs on remittance transfer errors in light of COVID-19 and government-mandated closings. This guidance states if a remittance transfer is not delivered to the recipient by the disclosed date of availability due to such closings, it’s not an error if it’s the result of extraordinary circumstances outside the remittance transfer provider’s control that could not have been reasonably anticipated…However, if the provider should have been able to anticipate the delay because, for example, the closings had already been announced at the time the remittance transfer was sent, it would be an error subject to the remittance transfer error resolution requirements.
In a May 12th blog, we alerted you to the fact that the threshold to determine whether you are subject to the remittance transfer rule will increase from 100 to 500, effective July 21, 2020. If you originated no more than 500 remittance transfers in the previous and current calendar year, you will not be subject to the rule come July 21st. However, if you had been covered under the rule (because you sent more than 100 remittance transfers in the previous or current calendar year), you still need to apply the applicable requirements to those transfers where payment was made prior to July 21st. This would include the requirements for error resolution.
Check out our June 2020 edition of Banking on BCC for more on the Remittance Transfer Rule Changes.
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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!