A “remittance transfer” is an electronic funds transfer requested by a sender (consumer in the United States) to a designated recipient (in a foreign country) that is sent by a remittance transfer provider. The definition is quite broad, but generally covers EFTs like international wire transfers and cross-border ACH transactions. It also covers transfers where a consumer provides cash or another method of payment to the credit union and requests that funds be sent to a specified location or account in a foreign country. And, under certain circumstances, the definition can also cover electronic bill payments scheduled in advance.
A “remittance transfer provider” is a “person” that provides “remittance transfers” for consumers in the “normal course of business” (regardless of whether the consumer holds an account with such person). Whether a credit union provides remittance transfers in the normal course of business depends on the facts and circumstances, including the total number and frequency of remittance transfers provided by the institution:
- If an institution provided 100 or fewer remittance transfers in the previous calendar year, and provides 100 or fewer remittance transfers in the current calendar year, then the institution is deemed not to be providing remittance transfers for a consumer in the “normal course of its business” and is exempt from the rule.
- If an institution crosses the 100-transfer threshold, and is then providing remittance transfers for a consumer in the normal course of its business, the final rule permits a “reasonable time period,” not to exceed six months, to begin complying with the remittance transfer rule.