[Kristin]

Is there any information about an incoming wire transfer that we are prohibited from giving our customer (the beneficiary)? For example, if we give the beneficiary a summary print out of the transaction, are we permitted to show the originator’s account number?

[donblaine]

Kristin,

An excellent question as I have not heard this issue discussed anywhere previously. I know of no law or regulation that would prevent your bank from sharing summary information that might include the originator’s account number from an incoming wire transfer payment order.

Regulation E is out of the discussion since wire transfers are exempted from the definition of an EFT and even if not exempted the Remittance Transfer rules only apply to the sending financial institution.

UCC Article 4A and FRB Regulation J do not specify what information from an incoming payment order can be transmitted to the beneficiary other than the amount and date of receipt.

I also see no issues relating to Regulation P and the sharing of NPPI. First, the sender of the wire is not your customer or consumer. Second, the re-disclosure of the account number appears to be Ok through the use of the Section 14 exception for processing and servicing transactions.

[Author]

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