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As summer comes to a close, you can count on a few things—cooler weather, changing leaves, and this year, a looming October 28 mandatory compliance deadline for remittance transfers. With just two months to prepare to institute new disclosure requirements for international electronic transfers, let’s walk through the top five action items to tackle.

5. Start Counting

Beginning in October, all remittance transfer providers will be required to comply with new Regulation E requirements governing electronic fund transfers. Your credit union is considered a remittance transfer provider if you send remittance transfers “in the normal course of business,” which the CFPB defines as more than 100 remittance transfers per year. If you conduct 100 or fewer transfers per year, you have a safe harbor. To determine if you are a remittance transfer provider, you must count all of the remittance transfers you originated in 2012.

Why 2012? It’s the look-back period. If you exceed 100 remittance transfers in the previous calendar year, you will be considered a remittance transfer provider in the current calendar year regardless of the actual number of remittance transfers you send. See the chart for help on safe harbor application.

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