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Course description

The CFPB’s Remittance Transfers rule has been in effect since October 2013 as subpart B of Regulation E. There was a September 2014 amendment that clarified the status of U.S. military installations overseas and certain other issues, and in June 2020 we got another set of amendments that increased the “safe harbor” exemption threshold from the rule to 500 remittance transfers.

Yet the regulation remains complex. There are provisions for delivering disclosures electronically, but they are limited. Some disclosures can be made orally, but only in specific situations. With the increased safe harbor amendments, insured banks and credit unions received broader exemptions from certain disclosure accuracy requirements, but with those exemptions came more complex recordkeeping to justify those exemptions.

The basics of the rule are unchanged. There are pre-purchase disclosures and receipt disclosures. Certain accuracy requirements are mandated (with some exceptions). A consumer has rights to cancel a transfer and, when things don’t go exactly as planned, to make claims of errors or non-delivery of funds.

In this two-hour presentation, BOL Guru John Burnett will explain –

  • Who is protected by the rule
  • Which transfers are covered
  • Transfers to U.S. territories and military installations overseas
  • The safe harbor limit on exemptions
  • Pre-purchase disclosures
  • When oral and electronically delivered disclosures are permitted (and when they are not)
  • Receipt disclosures and combined disclosures
  • Disclosure timing rules
  • The provision allowing estimates of exchange rates for certain countries
  • The provision for estimating covered third-party fees for certain transfers
  • The ins and outs of error resolution


John Burnett

John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc. and the team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.

Course curriculum

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