Dodd-Frank (Reg E) Foreign Wire Disclosure Frequently ...

1 Dodd-Frank (Reg E) Foreign Wire Disclosure Frequently Asked Questions (FAQ) General: 1) Q: What is Dodd-Frank (Reg E) Foreign Wire Disclosure ? A: New Section 1073 of the Dodd-Frank Act set forth new requirements for Foreign wire requests in order to provide protection for consumers when they request international electronic funds transfers. The Consumer Financial Protection Bureau (CFPB) issued a Final Rule, which will become effective on October 28, 2013, requiring that consumers be provided with certain disclosures and error resolution rights when sending electronic funds transfers outside the United States. 2) Q: What information are we required to disclose to the customer?

2 A: Any US-based consumers sending wires to a non US bank must receive both pre-payment disclosures and post-payment receipts that include: Full fee Disclosure at the time of initiation including Foreign currency conversion rate, fees imposed prior to receipt at the final institution, and any related transaction fees Final amount of funds to be received by the recipient, taking into account all fees Date of funds availability to the recipient Right of the sender to cancel transaction up to thirty (30) minutes after final approval by Fidelity Disclosure regarding resolution of inquiries, complaints, and returns Rights and recourse for errors 3) Q: Does this regulation apply to all wires?

3 A: No. This regulation only applies to wires that are going to a Foreign bank. 4) Q: Does a wire going to a territory such as Guam, the Virgin Islands or Puerto Rico fall within this regulation? A: No. Wires going to a territory are considered domestic wires and are not subject to the requirements of Dodd-Frank . 5) Q: What if my client is unavailable by phone, can you accept an email or other non-verbal form of confirmation? A: No. In order to comply with the regulation, Fidelity must verbally communicate the Disclosure information to the end client. 6) Q. If my advisor is able to call with the end client on the phone line, can we provide the Disclosure information in this manner?

4 A. Yes, as long as we can verify the end client's information, we can allow the advisor to connect us with the client. 200 Seaport Boulevard Z2B1, Boston, MA 02210 Clearing, custody, or other brokerage services may be provided by National Financial Services LLC or Fidelity Brokerage Services LLC, Members NYSE, SIPC. 7) Q: Once you ve spoken to the end client, will the wire be sent immediately? A: Pursuant to the new requirements, the end client must be given thirty (30) minutes in which they can decide to not send the wire. Therefore, the wire will be released to the Federal Reserve no earlier than 30 minutes after all internal approvals have been completed.

5 8) Q: Are all accounts covered by this regulation? A: No. Retirement accounts and Entity accounts ( partnerships, corporations, LLC s, Trusts) are excluded and are considered uncovered . 9) Q: What registration types are considered covered ? A: The CFPB regulation applies to accounts referred to as covered accounts, which include those with the following registrations: ADM-Administrator CM-Committee COMP-Community Property CV-Conservator FIDU-Fiduciary GD-Guardian I-Individual J-Joint WROS PR-Personal Representative TIC-Joint Tenant in Common TIE-Joint Tenant by Entirety TODE-Transfer on Death Joint Tenant by Entirety TODI-Transfer on Death Individual TODJ-Transfer on Death Joint WROS UF-Joint USUFRUCT UGMA-Custodial Uniform Gift to Minors UTMA-Custodial Uniform Transfer to Minors.

6 10) Q: Does the wire have to be received in dollars? A: No. If the end client holds a Foreign currency in their account, they can send a wire in that currency. Or, if they would like to convert the dollars held in their account to another currency, this can be done through our Foreign Exchange (FOREX) group. 11) Q: How do I contact the Foreign Exchange (FOREX) group? A: Your Service Team will be able to assist you through this process. 12) Q: What if the end client wants to have the dollars converted to another currency upon receipt at the Foreign bank, what do they need to do? A: In order to comply with the regulation to disclose fees and taxes associated with the delivery and receipt of a Foreign wire, all currency exchanges must be done through Fidelity s Foreign Exchange (FOREX) group.

7 13) Q: What if the end client has standing instructions on file with Fidelity, will you still have to call them? A: Yes. In order to comply with the regulation, Fidelity must verbally communicate the Disclosure information to your client for all transactions covered by the regulation. Impacts to Integrated Cashiering Platform (ICP) on Wealth Central: 14) Q: Are there changes to the Integrated Cashiering Platform (ICP)? A: Yes. In order to support the new requirements, we have made the following changes to ICP: Destination country will be required for all wires domestic and Foreign (US will be the default) The Bank ABA Number field has been re-titled Bank Routing Number When an international country is selected, the Payment Mode field defaults to SWIFT 15) Q: Are Foreign wires able to be processed through ICP now?

8 A: Yes. However, we still encourage you to submit Foreign wires to your Service Teams for processing due to the complexity with these transactions. Impacts to Standing Instructions: 16) Q: Are end client standing instructions still valid? A: While all standing instructions may still be valid, in order to comply with the requirements of the regulations, wire instructions that have been identified as having a Foreign bank as the destination bank will be disabled until the additional data elements can be obtained from you or your client. 17) Q: What are the additional data elements required for wire standing instructions? A: The additional data elements required for Foreign wires covered by the regulation are as follows: Destination country SWIFT/BIC code 18) Q: Do you have to receive the new data elements in writing?

9 A: No. As long as the original standing instructions aren t changing, we can accept the additional data elements via Service Center or verbally. 19) Q: Are other wire standing instructions impacted by these changes? A: Yes. If your client has wire standing instructions, including domestic instructions, that haven t been used within three (3) years, these instructions will be purged from ICP. 20) Q: If a wire standing instruction has been purged, can I call to have them reinstated? A: No. Once a wire standing instruction has been purged, a new Standing Instructions form must be submitted by your client to have the instruction re-established.

10 For investment professional use only. Fidelity Institutional Wealth Services, 200 Seaport Boulevard Z2B1, Boston, MA 02210 Clearing, custody, or other brokerage services may be provided by National Financial Services LLC or Fidelity Brokerage Services LLC, Members NYSE, SIPC.