Answer:
The facts you must consider are the location of the client's account from which funds are to be transferred and the location of the account that will receive the funds.
Apply these questions to the transfer:
- Is the client a natural person?
- Is the transfer primarily for personal, family or household purposes?
- Is the transfer to be completed electronically?
- Is the funding account located in an institution in a State (as defined in Section 1005.2)?
- Is the recipient's account located in other than a State (as defined in Section 1005.2)?
- Is the transfer amount greater than $15 U.S.?
If the answers to all six questions are "Yes," the transaction is subject to subpart B of Regulation E.
Based on your question, the funding account is located at a U.S. bank, which is located in a State, and the recipient bank is located in Canada, which is not in a State. The bad news, if there is any, is that the rule will apply to the fact situation you've described. The good news is that your bank will have complete control over and full knowledge of the disclosable costs (if any) and exchange rates needed to comply with the rule.
First published on BankersOnline.com 12/03/12
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