Does the regulatory definition of “remittance transfer” in 1005.30(e)cover this transaction?

Consumer accountholder provides their checking/debit card account number to a foreign merchant to purchase merchandise, and foreign merchant sends the transaction via ACH.

If not, is it because the ACH transaction wasn't "sent" by the Consumer and only consumer ACH originations are covered by the Reg.?

Thanks!

It is not a remittance transfer. The reason is because the definition only covers transactions which are originated at your institution. In your example, your institution is the receiver, not the originator. In addition to being originated by your institution, the transaction would also have to be for personal, family or household purposes...

See Reg E Subpart B (section 1005.30) for all of the definitions that relate to these new requirements - http://www.bankersonline.com/regs/12-1005/12-1005-000.html

Agree with tdogz. To be a remittance transfer, the ACH item would have to be an "outbound IAT credit" requested by your depositor to be originated from your institution. What you're describing is an "inbound IAT debit."

John, along the same lines of remittance transfers. is a personal investment account (via our brokerage dept) from which a consumer remits funds oversees subject to DF 1073? It is an investment account, not a deposit account, but is still an asset account. Your thoughts? Thanks.

The source of the funds doesn't matter if the Sender is a natural person and the remittance transfer is for a consumer purpose, with payment to be made to a person at a place outside a State (as State is defined in the regulation). If the Sender or the funding account is in a State, that clinches the definition.

BTW - John will be answering tons of bankers question in his Oct 26 webinar on the topic.

http://calendar.bollearningconnect.com/main.php?view=event&eventid=1344519681550