Question of the Week

  • QUESTION: With the change to the safe harbor thresholds for remittance transfer rules effective July 1, 2020, how does the bank determine if it can stop complying with the remittance transfer rules?

    ANSWER:

    If the bank provided 500 fewer remittance transfer in 2019 and provides 500 or fewer remittance transfers in 2020, the bank qualifies for the safe harbor and is not subject to the Remittance Transfer Rule in 2020 beginning on July 1, 2020. The safe harbor will also apply to the person's first 500 remittance transfers in 2021. 


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Question of the Week Archive

  • QUESTION: For the Regulation CC availability threshold adjustments, effective July 1, 2020, does the bank need to send a change in terms?

  • QUESTION: If the bank has hired a company to perform fraud protection and the company also markets to customers about the fraud protection services available, does the bank need to provide a Regulation P opt out to customers?

  • QUESTION: When there is a direct dispute of information on a credit report what is the furnisher’s responsibility?

  • QUESTION: The bank recently started taking applications via Skype. Does the bank need to collect monitoring information or is this type of application similar to a telephone application?

  • Q: A customer called the bank and asked for a stop payment 5 days before a scheduled preauthorized transfer. The bank requested written confirmation within 14 days. Does the bank need to honor the stop payment if written confirmation is not received?

  • QUESTION: A loan servicer has a situation where the borrower has an escrow account but does not have hazard insurance. If the borrower has an escrow account, may the bank force-place insurance?

  • QUESTION: What are the applicable exceptions under Regulation R for banks?

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