Answer:
Some banks are working with upstream correspondents to arrive at a workable solution. Some are considering whether becoming an agent for a "closed system" provider would resolve the problem for some international remittances. Some have determined that they are inside the "safe harbor" protection newly added to the rule, and will do what it takes to stay within the safe harbor. And some banks are contemplating exiting the business of providing consumer-initiated foreign remittances because of the risks and costs of non-compliance with the onerous disclosure and error-resolution rules.
First published on BankersOnline.com 1/21/13.