PwC's Managing upstream risk: Regulatory reform review - An asian perspective August 2013

• Fee disclosure – Disclosing foreign taxes or fees imposed by a recipient’s financial institution is now optional. • Smaller providers exempt – A company that does not exceed 100 remittance transfers annually is exempt from compliance. The initial concern with Section 1073 emanated from the fact that it affected overseas money transfers. Complexities related to foreign exchange rates and other factors make costs and fees unpredictable for all parties, thus creating frustration for consumers who often did not know what they would be charged. In an effort to create better transparency, the CFPB created standards that they believed were reasonable, but would have been impossible for many providers to meet. Integral Development Corp. on 5 August 2013 announced a filing with the CFTC to launch an SEF in compliance with agency’s recently passed SEF rules. In announcing the filing, Integral joins a roster of several players that have filed with the CFTC to launch SEFs under the Dodd Frank Act’s derivatives reform legislation. Bloomberg, which filed on 4 June 2013, is the first SEF approved by the CFTC. Tradeweb, MarketAxess, State Street and interdealer broker GFI have also submitted applications to launch SEFs, which the CFTC is expected to act upon. Trading by SEFs is scheduled to begin on October 2nd. Pending approval, Integral will be offering a regulatory-compliant FX trading platform with all necessary connections to liquidity providers, clearing houses, swap data repositories (SDRs), among other features. 2.5 Dodd-Frank Act Update The amended version of Section 1073 of DoddFrank comes as a welcomed regulatory change for FIs and remittance transfer providers as it carries positive implications for institutions that concentrate much of their business in electronic funds transfers, as well as creates opportunities for financial institutions to consider remittance transfers and provide a new service to their customers. The amendments include: • Liability limits – Error resolution provisions limit provider liability in cases where customers have given incorrect information, including wrong account numbers that have been passed on. Banking | Regulatory Reform Review 19

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