The Consumer Financial Protection Bureau recently revised the rule that implements Section 1073 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that creates certain protections for consumers who transfer money internationally (the “Remittance Rule”). The revisions are intended to preserve the new consumer protections provided under the  Remittance Rule while facilitating industry’s compliance with the rule.

The CFPB’s revisions to the Remittance Rule, include, among other things:

• disclosure of certain institution fees, and foreign taxes have been made optional (subject to certain disclaimer and/or exceptions);
• changes in provider obligations regarding errors from incorrect account information; and
• a new effective date of October 28, 2013.

As a result of the revisions to the Remittance Rule, financial institutions may need to update and revise their commercial agreements regarding international remittance and/or update their existing banking systems.

If you have any questions regarding the foregoing, please contact Andres A. Fernandez or Gabriel Caballero.

Read a copy of the revisions to the Remittance Rule.

This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.

Established in 1925, Gunster is one of Florida’s oldest and largest full-service law firms. The firm’s clients include international, national and local businesses, institutions, local governments and prominent individuals. Gunster maintains its presence in Florida with offices in Fort Lauderdale, Jacksonville, Miami, Orlando, Palm Beach, Stuart, Tallahassee, Tampa, The Florida Keys, Vero Beach and its headquarters in West Palm Beach. Gunster is home to more than 150 attorneys and 200 committed support staff, providing counsel to clients through 18 practice groups including banking & financial services; business litigation; construction; corporate; environmental & land use; government affairs; health care; immigration; international; labor & employment; leisure & resorts; private wealth services; probate, trust & guardianship litigation; professional malpractice; real estate; securities and corporate governance; tax; and technology & entrepreneurial companies. Gunster is ranked among the National Law Journal’s list of the 250 largest law firms.

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