MoneyGram 2015 Annual Report Download - page 11

Table of Contents
Dodd-FrankAct—The Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") was signed into law in 2010. The Dodd-Frank Act
imposes additional regulatory requirements and creates additional regulatory oversight for us. The Dodd-Frank Act created a Bureau of Consumer Financial
Protection (the "CFPB") which issues and enforces consumer protection initiatives governing financial products and services, including money transfer services, in
the U.S. The CFPB’s Remittance Transfer Rule became effective on October 28, 2013. Its requirements include: a disclosure requirement to provide consumers
sending funds internationally from the U.S. enhanced pre-transaction written disclosures, an obligation to resolve certain errors, including errors that may be
outside our control, and an obligation to cancel transactions that have not been completed at a customer's request. As a “larger participant” in the market for
international money transfers, we are subject to direct examination and supervision by the CFPB. We have modified our systems and consumer disclosures in light
of the requirements of the Remittance Transfer Rule. In addition, under the Dodd-Frank Act, it is unlawful for any provider of consumer financial products or
services to engage in unfair, deceptive or abusive acts or practices. The CFPB has substantial rule making and enforcement authority to prevent unfair, deceptive or
abusive acts or practices in connection with any transaction with a consumer for a financial product or service.
ForeignExchangeRegulation—Our money transfer services are subject to foreign currency exchange statutes of the U.S., as well as similar state laws and the
laws of certain other countries in which we operate. Certain of these statutes require registration or licensure and reporting. Others may impose currency exchange
restrictions with which we must comply.
RegulationofPrepaidCards—We sell our MoneyGram-branded prepaid card in the U.S., in addition to loading prepaid cards of other card issuers through our
ExpressPayment offering. Our prepaid cards and related loading services may be subject to federal and state laws and regulations, including laws related to
consumer protection, licensing, unclaimed property, anti-money laundering and the payment of wages. Certain of these federal and state statutes prohibit or limit
fees and expiration dates on and/or require specific consumer disclosures related to certain categories of prepaid cards. We continually monitor our prepaid cards
and related loading services in light of developments in such statutes and regulations.
Anti-BriberyRegulation—We are subject to regulations imposed by the Foreign Corrupt Practices Act (the "FCPA") in the U.S., the U.K. Bribery Act and similar
anti-bribery laws in other jurisdictions. We are subject to recordkeeping and other requirements imposed upon companies related to compliance with these laws.
We maintain a compliance program designed to comply with applicable anti-bribery laws and regulations.
Clearing and Cash Management Bank Relationships
Our business involves the transfer of money on a global basis on behalf of our consumers, our agents and ourselves. We buy and sell a number of global currencies
and maintain a network of settlement accounts to facilitate the funding of money transfers and foreign exchange trades to ensure that funds are received on a timely
basis. Our relationships with the clearing, trading and cash management banks are critical to an efficient and reliable global funding network.
In the U.S., we have agreements with six active clearing banks that provide clearing and processing functions for official checks, money orders and other draft
instruments. We employ four banks to clear our official checks and three banks to clear our retail money orders. We believe that this network of banks provides
sufficient capacity to handle the current and projected volumes of items for these services.
We maintain significant relationships with major international banks which provide the capability to transfer money electronically as well as through domestic and
international wire transfer networks. There are a limited number of banks that have the capabilities that are broad enough in scope to handle our volume and
complexity. Consequently, we employ banks whose market is not limited to their own country or region, and have extensive systems capabilities and branch
networks that can support settlement needs that are often unique to different countries around the world. In 2013 , we activated our participation in the Society for
Worldwide Interbank Financial Telecommunication ("SWIFT") network for international wire transfers, which improves access to all banks in the world while
lowering the cost of these funds transfers.
Intellectual Property
The MoneyGram brand is important to our business. We have registered our MoneyGram trademark in the U.S. and in a majority of the other countries in which
we do business. We maintain a portfolio of other trademarks that are material to our Company, which were previously discussed in the "Overview"section. In
addition, we maintain a portfolio of MoneyGram branded and related domain names.
We rely on a combination of patent, trademark and copyright laws and trade secret protection and confidentiality or license agreements to protect our proprietary
rights in products, services, expertise and information. We believe the intellectual property rights in processing equipment, computer systems, software and
business processes held by us and our subsidiaries provide us with a competitive advantage. We take appropriate measures to protect our intellectual property to
the extent such intellectual property can be protected.
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