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If the bank is still below the annual 500 remittance transfer threshold as of the amended Remittance Transfer Rule effective date, on what date may the bank cease compliance with the Remittance Transfer Rule?

In May 2020, the Consumer Financial Protection Bureau amended the Remittance Transfer Rule changing the definition of remittance transfer provider to include only those persons who make more than 500 remittance transfers a year, an increase from the previous 100 per year. As of mid-2020, my bank had sent less than 500 but more than 100 remittance transfers. If the bank is still below the 500 threshold as of the effective date of July 21, 2020, on what date may the bank cease compliance with the Remittance Transfer Rule?

Technically, the bank may cease complying on July 21, 2020 because it is under the new threshold. However, when evaluating whether to discontinue compliance, the bank should consider the likelihood that it might later exceed the 500 threshold, in which case it would have to again comply (within six months). In addition, banks should consider the customer relations impact of not providing disclosures, especially if the bank’s competition continues to provide them. (July 2020)

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