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18
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, including for matters related to unfair, deceptive, or abusive acts and practices. 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 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, such as future
registration requirements and increased regulation of forward contracts, 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 financial condition, results of
operations, and cash flows."
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.
201 FORM 10-K
5