Western Union 2014 Annual Report Download - page 156

2014 FORM 10-K
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Dodd-Frank Wall Street Reform and Consumer Protection Act and Other Similar Legislation
The Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") became United States federal law
in 2010. The Dodd-Frank Act created a new Consumer Financial Protection Bureau (the "CFPB") whose purpose is to implement,
examine for compliance with and enforce federal consumer protection laws governing financial products and services, including
money transfer services. The CFPB has created additional regulatory obligations for us and has the authority to examine and
supervise us and our larger competitors. The CFPB's regulations implementing the remittance provisions of the Dodd-Frank Act
have affected our business in a variety of areas. These include: a requirement to provide almost all consumers sending funds
internationally from the United States enhanced, written, pre-transaction disclosures, including the disclosure of fees, foreign
exchange rates and taxes, an obligation to resolve various errors, including certain errors that may be outside our control, and an
obligation to cancel transactions that have not been completed at a consumer's request. We have modified certain of our systems,
business practices, service offerings or procedures to comply with these regulations. We also face liability for the failure of our
money transfer agents and their subagents to comply with the rules and have implemented and are continuing to implement
additional policies, procedures, and oversight measures designed to foster compliance by our agents. The extent of our, and our
agents' implementation of these policies, procedures, and measures may be considered by the CFPB in any action or proceeding
against us for noncompliance with the rules by our agents. The CFPB has also implemented a direct portal for gathering information
regarding consumer complaints in the money transfer area. It is likely that this effort will lead to additional regulatory scrutiny.
Rules adopted under the Dodd-Frank Act by the Commodity Futures Trading Commission, as well as the provisions of the
European Market Infrastructure Regulation and its technical standards, which are directly applicable in the member states of the
European Union, have subjected most of our foreign exchange hedging transactions, including certain intercompany hedging
transactions, certain of the corporate interest rate hedging transactions we may enter into in the future, and certain of the foreign
exchange derivative contracts we offer as part of our Business Solutions segment, to reporting, recordkeeping, and other
requirements. Additionally, certain of the corporate interest rate hedging transactions we may enter into in the future may be subject
to centralized clearing and margin requirements and certain of our other transactions may become so in the future. Other jurisdictions
outside of the United States and the European Union are considering, have implemented, or are implementing regulations similar
to those described above. Derivatives regulations have added costs to our business and any additional requirements will result in
additional costs or impact the way we conduct our hedging activities as well as impact how we conduct our business within our
Business Solutions segment. For further discussion of these risks, see Part I, Item 1A, Risk Factors - "The Dodd-Frank Act, as
well as the regulations required by that Act and the actions of the Consumer Financial Protection Bureau and similar legislation
and regulations enacted by other government authorities, could adversely affect us and the scope of our activities, and could
adversely affect our operations, results of operations and financial condition."
Unclaimed Property Regulations
Our Company is subject to unclaimed property laws in the United States and in certain other countries. These laws require
us to turn over to certain government authorities the property of others held by our Company that has been unclaimed for a specified
period of time, such as unpaid money transfers and money orders. We hold property subject to unclaimed property laws and we
have an ongoing program designed to help us comply with these laws. We are subject to audits with regard to our escheatment
practices.