The Bank is currently engaged in intermediary wires transactions with one of our affiliates. The afiliate overseas sends us intermediary wires to us, and we charge a flat fee of "A" per transaction. The bank set up a nostro account in the affiliate bank for the purpose of the funds transfer settlment.

According to the outside legal counsel, opening nostro or vostro accounts for funds transfers with affiliates is not covered by 23A and Regulation W.

We are about to engage in similar intermediary wire transaction with another affiliate, but we would like to lower the fee per transaction for the affiliate.

If the transaction is not covered transaction under Regulation W, section 23B still applies? I mean, can we charge different fees for the same service to different affiliates? we would like to charge the same, however, the affiliate banks carry the fee over to the customers, and they charge fixed amount to the customer, and the difference between the fee to the customer and the fee charged by us, they have to cover.

What kind of regulation govern this situation?

Thank you in advance,

And your BSA dept is aware of this business practice?

The practice has yet to be established. BSA dept. was also included in the discussion. They have told us that each must be monitored by sample testing and due diligence.