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The Dodd Frank Act: Changes To Remittance Transfers Heartland Compliance August 09, 2011 Lisa Valentine Senior Vi

Federal Reserve Regulation E Docket No R-1419. Final Rule:Effective January 21, 2012. Introduction. ?The proposal contains new protections for consumers who send remittance transfers to consumers or entities in a foreign country, by providing consumers with disclosures and error resolution rig

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The Dodd Frank Act: Changes To Remittance Transfers Heartland Compliance August 09, 2011 Lisa Valentine Senior Vi

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    1. The Dodd – Frank Act: Changes To Remittance Transfers Heartland Compliance August 09, 2011 Lisa Valentine Senior Vice President, Operations Bankers’ Bank of Kansas, N.A.

    2. Federal Reserve Regulation E Docket No R-1419 Final Rule: Effective January 21, 2012

    3. Introduction “The proposal contains new protections for consumers who send remittance transfers to consumers or entities in a foreign country, by providing consumers with disclosures and error resolution rights.” Federal Reserve System: 12 CFR Part 205 Electronic Funds Transfer

    4. While the intentions were good…

    5. Did They Consider… What is a Remittance Payment? What is NOT a Remittance Payment? Who is the Designated Recipient? Who is the Transfer Provider? How can a sender identify ALL of the intermediaries and their fees? How will proposal address disclosures for mobile devices?

    6. We Need Answers First The proposal does not distinguish between “open” and “closed” networks. How do the projected operational changes for compliance impact community banks with correspondent relationships? Will technical and operational costs for implementation overburden community banks? Will new requirements put community banks at a competitive disadvantage?

    7. Unintended Consequences Excessively broad definitions. Overburdens the provider and creates obligations that are impossible to fulfill. Promotes conditions that will increase consumer fraud. The final rule could force some providers out of the market. Will increase costs for the same consumer the rule was intended to protect.

    8. What happens when… your customer wants to send $100.00 U.S. to a family member in Mexico? your customer is sending funds for humanitarian aid to a third world country? your prominent commercial customer has sent a large wire to a country with potential sanctions, and the beneficiary reports non-receipt?

    9. Is this really good for the consumer?

    10. Thank You!

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