Quick Reference Guide
Online Courier: Disclosure Requirements for Remittance Transfer Rule
http://onlinecourier.suntrust.com
As of October 28, 2013, the Consumer Financial Protection Bureau (CFPB) implemented the Remittance Rule Implementation (Subpart B of Regulation E - the “Remittance Transfer Rule”). The details of the ruling can be found on the following website: consumerfinance.gov/remittances-transfer-rule-amendment-to-regulation-e/#summary. The Remittance Transfer Rule requires that consumers sending overseas wire transfers receive prepayment disclosures and receipts setting forth certain information with respect to the transaction. This guide shows you how SunTrust supports the delivery of the required prepayment disclosures and the receipts to a financial institution’s consumer clients wishing to send wire transfers overseas, and it may also be used by agents initiating international wire transfers from consumer accounts through Online Treasury Manager or Online Foreign Exchange.
The Online Courier Remittance Transfer process is a stand-alone reporting service which is not connected to Online Treasury Manager or Online Foreign Exchange. This process is used exclusively for generating disclosures and receipts; Online Courier does not generate the actual wire transfer. Consumer international wires will still need to be initiated separately.
Getting Started
For navigation and security information regarding Online Courier, please click the Product Information link and reference the User Reference Materials page.
Signing On
To Access Online Courier
1. Enter your Company ID, User ID, and Password. 2. Click Sign On.
Note: Sign-on information is case-sensitive. If you enter your password incorrectly three times in a row, your User ID will be locked. Contact the SunTrust Technical Services Group at 877.785.6925, option 3 to unlock your User ID. If you are signing on for the first time, the system will prompt you to enter and then reenter a new password. Enter the information and click the Sign On button.
Generating Disclosures and Receipts IMPORTANT NOTE for first time financial institution users: Before generating disclosures and receipts which comply with Reg E
requirements, the financial institution’s security administrator must enter their related Financial Institution Error Resolution and handling, and originating bank fees as
applicable. Refer to Exhibit 1 for sample text. This one-time setup step can be accomplished by clicking the Wire Disclosure Admin link under the Payments & Transfers tab. Financial institutions are not permitted to use SunTrust Bank disclosure text, and must uncheck the Use Bank Defaults box. These disclosures are
2 To Generate Disclosures and Receipts
1. Under the Payments and Transfers tab, select the Wire Disclosures link. The Wire Disclosures page appears.
2. Complete the Wire Disclosure form based on the information provided by the consumer debit party. Refer to Exhibit 2 for further explanation of the fields on this form.
3. After completing the required information as well as any optional fields, check the Do you accept the addendum to the Terms and Conditions? box at the bottom of the page.
Note: The addendum is available on the Online Courier User Reference Materials page, accessible within the service from the Product Info link.
4. Click the Review button. The Pre-Payment Disclosure and Receipt will display in English and Spanish for your final review.
5. If you need to make changes, click the Edit button. Otherwise, click the Submit button. A confirmation message will display, and the disclosures will be sent to the email address on your Online Courier Profile. You can print disclosures by clicking the Print button.
Important Notes
A wire should not be released by a financial institution* or agent through Online Treasury Manager or Online Foreign Exchange before the 30 minute waiting period, and the consumer debit party has the right to cancel the payment within that 30 minute waiting period.
When a consumer debit party (“sender”) furnishes an incorrect account number or bank identifier, there are five conditions that must be met in order for a remittance transfer provider to avoid liability. First, the remittance transfer provider must demonstrate that the sender furnished an incorrect account number or bank identifier. Second, where the error is an incorrect identifier for the receiving institution, the remittance transfer provider must use “reasonably available means” such as commercially available databases or directories to verify the bank identifier, if it is feasible to do so. Third, the remittance transfer provider must give notice before the sender authorizes the remittance that an incorrect account number or bank identifier may cause the funds to be misdirected and the sender could lose the funds; the rule does not specify a notice other than requiring it to be clear and conspicuous, but the notice can be given orally if the prepayment disclosure is provided orally. Fourth, the remittance transfer provider must demonstrate that the funds were deposited to the wrong account.** Finally, the remittance transfer provider must use reasonable means to attempt to recover the funds of the sender.**
Where indicated, fees, amounts, taxes, and rates will be estimated depending on the currency and the country where the funds are being sent. Recipients may receive less than the transfer amount due to fees charged by recipient’s bank and foreign taxes.
If a Foreign Exchange contract was purchased (through any channel) and the consumer debit party cancels the payment within the 30 minute waiting period, the financial institution or agent which obtained the contract must immediately contact the SunTrust Foreign Exchange Desk by calling 800.494.9782. Any losses associated with Foreign Exchange contracts that are cancelled will be charged directly to the financial institution or agent (please refer to the addendum for definition) and will not be incurred by SunTrust.
Online Courier provides three years of wire disclosure record retention, available in the Resend queue at the company or user levels.
*Financial institution as defined in the Financial Institution Remittance Transfer Addendum. ** SunTrust may be able to provide assistance with researching this condition.
Exhibit 1: Disclosure Party and User Interface Field Definitions
Party/Field Definition
Bank to Bank Information Bank to Bank information provided by the consumer debit party
Contract Field Checkbox to allow for the entry of a foreign exchange contract number and
associated rate. Contracts apply to Online Foreign Exchange transactions and transactions with the Foreign Exchange Desk
Debit Party Consumer who holds an account at the financial institution as defined in the
Financial Institution Remittance Transfer Addendum
Debiting Account Field Consumer debit party’s account number
Disclosure/Receipt Currency
Display Changes the currency display for specific areas of the disclosure
Exchange Rates Exchange rates for selected currency
Financial Institution Financial institution as defined in the Financial Institution Remittance Addendum
4
Originator to Recipient Information
Originator to recipient/beneficiary information as provided by the consumer debit party
Originating Bank Fees Field Optional fees that may be added/removed by the financial institution to pass on
to the consumer debit party
Process Currency Field Currency that consumer debit party wants to send
Recipient/Beneficiary The party who will receive the funds per the instructions provided by the
consumer debit party
Recipient/Beneficiary Bank The recipient’s Bank information (SWIFT address)
Disclosure Text: Financial Institution Error Resolution Information. This information must be entered into Online Courier by the financial institution’s security administrator.
SAMPLE ONLY: You have the right to dispute errors in your transactions. If you
think there is an error, contact us within 180 days at 800.XXX.XXXX or
www.financialinstitution.com. You can also contact us for a written explanation of your rights. You can cancel for a full refund within 30 minutes of payment, unless the funds have been picked up or deposited. For questions or complaints about Your Bank, contact:
Georgia Department of Banking and Finance 2990 Brandywine Road, Suite 200
Atlanta, Georgia 30341-5565
(888) 986-1633 or http://dbf.georgia.gov/
Consumer Financial Protection Bureau 855-411-2372
855-729-2372 (TTY/TDD) or www.consumerfinance.gov Exhibit 2: Definitions Related to Prepayment Disclosure and Receipts
Transfer Fees are the amount in USD that
is charged to the consumer debit party by the financial institution where the wire is originated.
Other Fees and Other Taxes are the amounts in
USD or other currency that are charged by the correspondent banks.
Exchange Rate is the foreign currency rate
applied to the transfer. If entered, the contract number will display next to the rate.
Date of Availability is seven business days after the
expected value date; funds may be available sooner. Value Date is two business days after the
Send Date, excluding applicable holidays. Transfer Amount is the amount in USD (or
other currency if box is checked for Disclosure Receipt Currency Display) that is being requested to be sent by the consumer debit party.
Time is the time that the disclosure was generated
Signing Off To Sign Off
Click Sign Off at the top right of each page to end your Online Courier session. The system confirms that you have successfully signed off and provides a Sign On button you can use to sign back on.
Getting Help
Click Help at the top or right side of any page.
If your User ID or Password becomes locked out, please contact your company administrator about resetting your User ID and Password.
If you need technical assistance, please contact SunTrust Treasury Management Technical Services at
877.785.6925, option 3. Representatives are available from 8:00 a.m. to 6:00 p.m. EST Monday through Friday on bank business days. For all your other servicing needs, including any services outlined in this document to which you do not currently subscribe, please call your company’s Treasury Management Client Services Specialist.
