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We are encroaching on the remittance transfer safe harbor of 100 for 2017. It has been while, 2013, since we hit our 101st transfer. In 2014, we provided the disclosure because we didn’t have 100 or fewer transfers in 2013. However, in 2015 and 2016, we did not exceed the 100 threshold.
Our question is would we be granted another transition period (not to exceed six months) or would we need to comply immediately? We had been informed it was immediately; however, I am unable to find this in the regulation.
Your assistance is much appreciated!
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