Full text of District Notices (Federal Reserve Bank of Dallas) : Federal Reserve Proposes Rule Under Regulation E to Create New Consumer Protections for Remittance Transfers, Notice 11-31 : Summary of Findings

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TABLE OF CONTENTS
Executive Summary

Chapter I: Background

Chapter II: Exploratory Focus Groups

Methodology

Key Findings

Chapter III: Development of Model Disclosure Forms

Chapter IV: Testing of Disclosure Forms

Methodology

Round 1: Interviews in New York, New York (January 2011)

Round 2: Interviews in Atlanta, Georgia (February 2011)

Round 3: Interviews in Bethesda, Maryland (March 2011)

Chapter V: Conclusion
Appendices
Appendix A: Sample Recruitment Screeners
Appendix B: Participant Demographic Information
Appendix C: Model Disclosures Used in Testing

EXECUTIVE SUMMARY
Background and Description of Project
In July 2010, President Obama signed into law the Dodd-Frank Wall Street Reform and Consumer
Protection Act (the “Dodd-Frank Act”). Section 1073 of the Dodd-Frank Act requires the Board of
Governors of the Federal Reserve System (“the Board”) to develop and implement new disclosure
regulations for remittance transfer providers. Beginning July 21, 2011, the Consumer Financial
Protection Bureau (“CFPB”) will assume this responsibility. Until the transfer of these
responsibilities to the CFPB, the Board is responsible for developing these new regulations, as well
as model disclosures that illustrate how the required information can best be provided to
consumers. The primary goal of these new disclosures is to ensure that consumers who send
remittances are aware of the full costs that they are paying to send money to other countries.
In November 2010, the Board contracted with ICF Macro, an ICF International company, to assist
it with this effort. ICF Macro is a research and evaluation company with expertise in the design and
cognitive testing of effective consumer communication materials. In recent years, ICF Macro has
also worked closely with the Board on its reviews of disclosures related to credit cards, mortgages,
overdraft protection, and funds availability.
The findings from this work informed the Board’s proposed disclosure regulations for remittance
transfer providers, which are expected to be published for public comment in spring 2011.
The revised disclosure forms that were developed and refined through the testing will be used as a
basis for the model forms included with the proposal.

Methodology
The research for this project consisted of three phases. In the first phase, ICF Macro conducted
three exploratory focus groups with consumers in Bethesda, Maryland and three in Los Angeles,
California to learn about how they make decisions related to remittances and what information is
useful to them in this context. ICF Macro and Board staff worked collaboratively to design
a protocol that would gather information about the factors consumers consider when choosing a
remittance transfer provider, what information they receive from providers before and after their
transaction, the utility of information provided prior to completing a transaction or on a
storefront posting or on the internet, and their experience dealing with errors in remittance
transactions. In each location, two of the focus groups were conducted in English, while the other
was conducted in Spanish. The research protocol was the same for the English- and Spanishlanguage groups.
In the second phase of the project, information designers at ICF Macro drew from focus group
findings to develop disclosure forms consistent with the requirements of the Dodd-Frank Act.
Four types of disclosure forms were designed to be used for cognitive testing with consumers:
a pre-transaction disclosure, post-transaction disclosure, combined pre/post-transaction
disclosure, and notification of confirmation code. These disclosure forms were modified after
each set of cognitive interviews.

Summary of Findings:
Design and Testing of Remittance Disclosures

In the final phase of this project, ICF Macro conducted in-depth cognitive interviews with
consumers in New York, New York; Atlanta, Georgia; and Bethesda, Maryland. ICF Macro and
Board staff worked collaboratively to develop a protocol that would test participants’
understanding of and reactions to the timing and content of the disclosure forms. The forms were
presented in the context of scenarios in which the participant requested a remittance transfer and
received disclosures. In order to avoid order effects, the interviewer alternated the order in which
scenarios were presented. Following each round of testing, the disclosure forms were refined to
reflect findings from the interviews.
Participants for the focus groups and interviews were recruited by telephone using structured
screening instruments developed collaboratively by ICF Macro and Board staff. The screening
instruments were designed to ensure the recruitment of participants with a range of ages, education
levels, amount of time lived in the United States, and geographic region to which money is sent.
For the interviews, an item was also added to ensure the recruitment of participants whose primary
language was not English.

Summary of Key Findings
Phase I: Exploratory Focus Groups
How Participants Choose Remittance Transfer Providers

•

The most important factors to participants when choosing a remittance transfer provider
were the amount of fees charged, the convenience of locations for the recipient, and the
convenience of locations for the sender. Some participants said that these factors could
vary depending on the situation. For example, a low fee might be the most important
consideration when sending routine remittances, but speed and reliability were more
important when sending money for emergencies.

•

Most participants said they were satisfied with their experience sending remittances and
typically use the same provider every time they send money. Some participants
commented that using the same provider resulted in conveniences that were more
important to them than receiving a slightly better exchange rate or fee elsewhere.

•

A few participants said they routinely compared providers, usually by looking for the
most favorable fees. Some of those who routinely sent money in local currency said they
compared exchange rates.

Information Received from Providers Before and After In-Person Transactions

•

Most participants said that when they get their receipt they review the recipient’s name,
the location to which the money is being sent, and the amount of money the recipient will
receive. Most participants said that they did not carefully read any other information on
the receipt, although a few participants said they reviewed other information as well.

•

Most participants said they keep their transaction receipt until they know the recipient has
received the money. A few participants said they save their receipts for a longer period of
time for their own records.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

Most participants said they did not get any written information before completing an inperson remittance transaction, but could get information such as fees and exchange rates
orally, if they asked an agent.

Information Received from Providers Before and After Online Transactions

•

In contrast to what was said by those participants who make in-person transactions, those
who send money online get a great deal of specific information before completing the
transaction, including: fees, exchange rate, when the funds will be available, and the
amount of money that will be available to the recipient. These participants believed that
this information was an exact quote (not an estimate) but that it would only be guaranteed
accurate for that specific transaction. Most participants said they were also given this
information after the transaction through a confirmation screen and/or via email.

•

Participants who send money online generally keep a record of their transactions for
longer than those who send money in person. Most of these participants either said they
save the receipts they get in their email or that the website they use to send the money
keeps a history of their transactions.

Reactions to the Idea of Receiving Pre-Transaction Information

•

Most participants indicated that it would be useful to receive some information prior to
completing the transaction, specifically: the amount to be received, fees associated with
the transaction (including any to be paid by the recipient), how fees are determined,
exchange rate, and date of availability.

•

Participants were divided as to whether they thought pre-transaction information should
be given on paper, orally, or on a screen. Approximately half of the participants wanted
the information on paper. Most of these participants felt it would serve as proof of what
they were told if they subsequently had a problem. A few participants said that
information on paper would facilitate making comparisons between providers. Those
participants who did not want pre-transaction information to be provided on paper felt
that it would unnecessarily complicate a simple process, was unnecessary for anyone
familiar with the process of sending money, and opened up the possibility that if they
received too many papers they might confuse the papers and accidentally discard the one
with their confirmation code (which is necessary for the recipient to pick up the money).

Reactions to the Idea of Posting Information on a Storefront or Online

•

When asked about the usefulness of a storefront posting that showed how much a
recipient would receive in local currency if $100 were sent, most participants responded
by highlighting limitations of such a posting. They felt that providing comprehensive
information on a storefront posting would be difficult, given that most providers send
money to multiple countries with different exchange rates and that transfer fees could
vary based on multiple factors (such as the speed with at the money was sent).
Participants were also skeptical that providers would be able to keep exchange rate
information up-to-date on a storefront posting.

iii

Summary of Findings:
Design and Testing of Remittance Disclosures

•

There were several participants who did think such a storefront posting could be useful to
them. A few participants thought it could serve as a reference point for comparing
providers, and that reviewing a posting would be more convenient than waiting in line to
get the information. Some other participants said they might use the storefront posting to
determine when to send a remittance based on fluctuations in the exchange rate, but not to
compare different providers.

•

Some participants suggested that a simpler posting that disclosed transfer fees would be
more useful. However, others felt that even a posting that focused specifically on fees
could be very complex because of the multiple reasons that fees can vary.

•

Most participants said that unless the information shown on the storefront posting was
dramatically different from what they expected, they would follow through with their
intended transaction.

•

Participants who send money online said that the provider typically gives them a
real-time exact quote that is specific to the transaction they intend to make. Therefore,
these participants said that an online disclosure containing information similar to that of
the hypothetical storefront posting would not be useful.

Dealing with Errors or Problems

•

Most participants reported experiencing problems with at least one remittance transaction
in the past. In the vast majority of cases, participants said their problems had been
resolved fairly quickly, and that the recipient had eventually received the money.
The most common problem was that the agent or sender had spelled the recipient’s name
incorrectly, and that as a result, the recipient had difficulty picking up the money. A few
participants mentioned experiences in which the recipient had been charged unexpected
taxes or fees, or frustration due to delays in the availability of the funds when the money
was time-sensitive and critical (such as for a hospital bill).

•

Only two participants described situations in which they felt the provider had not
satisfactorily resolved an error. One participant said that the provider had lost his money,
and as a result, the participant no longer used that provider. The other participant felt that
she had been overcharged by her provider; it was unclear whether she still used that
provider. A few other participants also said they had changed providers because they
were unhappy with the error resolution process, even though the problem was resolved
in the end.

•

Most participants indicated that they were aware that their receipt contained information
about what to do in the case of an error. However, most participants also said they had
never read this information. In the event of an error, most participants either contacted the
provider by phone or went back to the location where they sent the money.

Summary of Findings:
Design and Testing of Remittance Disclosures

Phase II: Development of Disclosure Forms
Four types of disclosure forms were developed for testing:
•

Pre-Transaction Disclosure: This disclosure (referred to as the “P” form) would be
given to consumers before they paid for the transaction. This disclosure included the
phrase “not a receipt” at the top of the document, as well as the transfer amount, transfer
taxes and fees, the total transaction amount (i.e., the total amount paid by the sender to
the transfer provider), the exchange rate, the transfer amount expressed in local currency,
other taxes and fees, and the total amount of money (in local currency) that would be
available to the recipient.

•

Post-Transaction Disclosure: This disclosure (referred to as the “T” form 1) would be
given to consumers after they completed the transaction. It included the word “receipt” at
the top of the document, as well as all of the information provided in the P form. In
addition, it provided the name, address, and phone number of the sender; the name and
address of the recipient; the address of the location where the recipient would pick up the
funds; the date the funds would be available; the confirmation code; a statement about the
sender’s error resolution rights; and contact information for the money transfer provider,
the state regulatory agency, and the Consumer Financial Protection Bureau. In later
rounds, a statement about the sender’s cancellation rights was added.

•

Combined Pre/Post-Transaction Disclosure: This disclosure (referred to as the
“CP” form) combined the timing of the P form (i.e., pre-transaction) with the content of
the T form. It originally included the phrase “not a receipt” at the top (like the P form),
although this phrase was removed in later rounds.

•

Notification of Confirmation Code: This form (referred to as the “C” form) would be
given to consumers after they completed the transaction. It was a smaller piece of paper
than the other forms, and contained only the confirmation code that would be associated
with that transaction.

Phase III: Testing of Disclosure Forms
Comprehension of Disclosure Forms

•

Across the three rounds of testing, nearly all participants understood the information
presented in the disclosure forms, including: the date the funds would be available,
transfer fee, transfer amount, total transaction, exchange rate, and the total amount that
would be available to the recipient in local currency. A few participants misinterpreted
the “other fees and taxes” shown on the form to be the transfer fee converted to local
currency, rather than a separate charge on the receiving end of the transfer.

•

When shown disclosures that indicated that fees or exchange rates were “estimated,” all
participants understood this meant that the actual amounts might be different from those

An alternate version of the T form (referred to as the “ET” form) was also developed. The ET form was identical to the T form
except that it included wording that would be used if a provider were unable to provide exact terms for a transaction. The ET form
was not shown to participants as part of a scenario, but was used to test their comprehension of the revised text.

Summary of Findings:
Design and Testing of Remittance Disclosures

shown. Most participants believed that the provider might show estimated terms because
they could vary based on fluctuations in the exchange rate.
•

In Round 1 of testing, one of the disclosures shown to participants indicated that funds
would be available “on or before” a given date. This was intended to convey that the
funds would definitely be made available by the given date, and might be made available
before that date. Nearly half of the participants incorrectly interpreted this to mean that
the funds would be available any time between the day of the transaction and the given
date, but not after that date. For Round 2, this phrase was changed to “available by.”
However, nearly all participants misinterpreted this to mean that the funds would be
available on or after the given date, but not before. For Round 3, this phrase was changed
to “date available,” and the phrase “(may be available sooner)” was added.
All participants correctly understood this to mean that the funds would definitely be
available on or after the date given, and that they also might be available before.
Therefore, the wording from Round 3 was used in the Board’s proposed model forms.

Timing of Information

•

Across all three rounds of testing, most participants said that getting information prior to
completing the transaction could be useful in that it would give consumers the
opportunity to review or confirm information before sending the money. A few
participants suggested pre-transaction information could also be used to determine the
amount of money that should be sent to ensure the recipient received a certain amount of
local currency. However, some participants said they did not understand why they would
get a pre-transaction disclosure with this information, when the exact same information
was given on the post-transaction disclosure.

•

Most participants did not have a strong preference for how pre-transaction information
should be presented. A few participants felt that it would be best to provide this
information on paper because it (a) would be easier for senders for whom English is not
the primary language they speak, (b) could serve as proof of what consumers were told,
or (c) that it would be more helpful to those unfamiliar with the process. Some other
participants felt that providing this information on paper was wasteful and that it could be
communicated orally or on a screen.

•

In the first round of testing, two scenarios were described to participants. In the first
scenario, they received the P form before the transaction and the T form after the
transaction was complete. In the second scenario, they received the CP form before the
transaction and the C form after the transaction was complete. Only two participants said
they preferred the CP scenario. These two participants liked that there was so little
information on the post-transaction disclosure. One felt it protected the sender from
identity theft, while the other believed it protected the transaction from theft. The other
eight participants preferred the P/T scenario–either because they liked that one piece of
paper contained all of the information, or because they felt the T form could serve as
proof that the transaction occurred whereas the C form could not. Because the majority of
participants responded negatively to receiving the confirmation code alone on a piece of
paper, in subsequent rounds the C form was not used, and the confirmation code was
included on the CP form.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

In Rounds 2 and 3, two scenarios were described to participants. The first scenario was
the same as Round 1—they received the P form before the transaction, and the T form
after the transaction was complete. In the second scenario, participants received only the
CP form before the transaction (which included the confirmation code), and nothing
afterward. About half of participants in Rounds 2 and 3 said they preferred the
CP scenario. Some liked the opportunity to review all of the information prior to the
transaction, while others preferred receiving only one piece of paper. The other half of
participants preferred the P/T scenario. These participants felt it was important to receive
a disclosure after the transaction was complete; some pointed out that the T form could
serve as proof the transaction occurred, whereas the CP form could not.

•

Some participants who preferred the P/T scenario were asked if they would be more
comfortable receiving CP if the clerk stamped it following the transaction to indicate the
money had been sent. While nearly all of these participants felt that such a stamp would
improve the usefulness of that disclosure, most still said they would prefer to get a piece
of paper after the transaction.

•

When asked whether they thought the information provided on a pre-transaction
disclosure would be an estimate or exact, nearly all participants believed it would be
exact. Most participants believed that the terms shown on the pre-transaction disclosure
would be accurate for at least an hour, but might change the following day due to
fluctuations in the exchange rate.

•

When asked how long they would keep the different disclosure forms, most participants
said they would hold onto the combined pre/post- or post-transaction disclosures (CP or
T forms) at least until the recipient received the money. They generally indicated that
they would keep the pre-transaction disclosure (P form) for a shorter period of time;
many participants said they would throw it away immediately.

Error Resolution Rights

•

When reviewing the forms, several participants commented that they liked the fact that
the error resolution information was presented concisely.

•

When asked what they would do if they learned that the intended recipient did not receive
the money, most participants said they would contact the provider using the number
provided on the disclosure forms. Other participants said they would first go back to the
place where they made the transaction to resolve the issue in person.

•

Almost all participants saw the contact information provided on the form for the state
regulatory agency and the Consumer Financial Protection Bureau. When asked what
they would do if they had exhausted all their options with the provider but the problem
had not been resolved, most participants indicated that they would contact these
agencies. A few participants did not believe these agencies would be the most effective
way of resolving the issue, and said they would instead contact the Better Business
Bureau, the police, or a lawyer.

vii

Summary of Findings:
Design and Testing of Remittance Disclosures

Cancellation Rights

•

Participants in Round 2 were asked if they believed they had the right to cancel the
transaction once it was complete. 2 Slightly more than half of participants thought they
might be able to cancel as long as the recipient had not picked up the money, while the
remaining participants did not think they could cancel the transaction. After reviewing an
additional disclosure that included language about their cancellation rights, most
participants understood they would have a right to cancel. However, the amount of time
they thought they could cancel varied widely. In Round 3, the language about
cancellation rights was revised to clarify that the sender had the right to cancel the
transaction within 24 hours. All participants understood this information.

•

In Round 2 and the first day of Round 3, participants thought that if they cancelled the
transaction they would not be refunded the transfer fee they had paid. On the last day of
testing, the forms were modified to indicate that the sender may have the right to a
“full refund.” Most participants understood this to mean that the refund would include the
transfer fee. Therefore, the wording from the second day of testing during Round 3 was
used in the Board’s proposed model forms.

•

All but one of the participants understood that they would not be able to cancel a
transaction if the money had already been picked up by the recipient.

In Rounds 1 and 2, the disclosures used for the scenarios did not include any information about consumers’ right to cancel.

viii

CHAPTER I: BACKGROUND
In July 2010, President Obama signed into law the Dodd-Frank Act. Section 1073 of the
Dodd-Frank Act requires the Board to develop and implement new disclosure regulations for
remittance transfer providers. Beginning July 21, 2011, the CFPB will assume this responsibility.
Until the transfer of these responsibilities to the CFPB, the Board is responsible for developing
these new regulations, as well as model disclosures that illustrate how the required information can
best be provided to consumers. The primary goal of these new disclosures is to ensure that
consumers who send remittances are aware of the full costs that they are paying to send money
to other countries.
In November 2010, the Board contracted with ICF Macro, an ICF International company, to assist
it with this effort. ICF Macro is a research and evaluation company with expertise in the design and
cognitive testing of effective consumer communication materials. In recent years, ICF Macro has
also worked closely with the Board on its reviews of disclosures related to credit cards, mortgages,
overdraft protection, and funds availability.
The research for this project has consisted of three different phases. First, ICF Macro conducted a
series of six exploratory focus groups with consumers who send remittances to learn more about
how they make decisions related to remittances and what information is useful to them in this
context. Following these groups, ICF Macro’s information designers developed a set of model
disclosure forms that met the requirements of the Dodd-Frank Act and would be understandable
and useful to consumers. In the final phase of the project, these model forms were tested through
three rounds of in-depth cognitive interviews with consumers. The forms were revised between
rounds to address any usability or comprehension issues that became apparent.
The findings from this work informed the Board’s proposed disclosure regulations for remittance
transfer providers, which are expected to be published for public comment in spring 2011.
The revised disclosure forms that were developed and refined through the testing will be included
as model forms with the proposal.

CHAPTER II: EXPLORATORY FOCUS GROUPS
Methodology
In order to learn more about how consumers make decisions related to sending remittances and
what kinds of information they would find most useful, ICF conducted a series of six focus groups
with consumers who send money to other countries. Three groups were held in Bethesda,
Maryland on December 2 and 7, 2010, and three were held in Los Angeles, California on
December 14, 2010. A total of 56 consumers participated in the groups. In each of the two
locations, two of the focus groups were conducted in English, while one was conducted in Spanish.
Recruitment for the Spanish-language group was conducted in Spanish, but all recruiting criteria
were essentially the same as for the English-language groups.
Focus group participants were recruited by telephone using a structured screening instrument
developed by ICF Macro and Board staff. Participation was limited to consumers who send money
to a person or a company in another country at least once per year, and who do not work in the
financial industry. Other questions ensured the recruitment of participants with a range of ages,
education levels, amount of time lived in the United States, and geographic region to which money
is sent. The recruiting screener used for the Bethesda groups is provided as Appendix A;
the screener used in Los Angeles was essentially the same. Information about participants’
demographic and background characteristics is provided in Appendix B.
Each of the focus groups lasted approximately 90 minutes, and was conducted using a protocol that
was developed collaboratively by ICF Macro and Board staff to guide the discussion. Participants
were asked about the factors consumers consider when choosing a remittance transfer provider,
what information they receive from providers before and after their transaction, the utility of
information provided prior to completing a transaction or on a storefront sign, and their experience
dealing with errors in remittance transactions. The same protocol was used in the Spanish- and
English-language groups.

Key Findings
How Participants Choose Remittance Transfer Providers
•

Participants were asked to list the factors they consider when choosing a provider.
Factors mentioned by participants, in approximate order of frequency, included:


Amount of fees charged



Convenience of locations to the recipient



Convenience of locations to the sender



Reliability of the provider



Time it takes for the money to become available



Exchange rate

Summary of Findings:
Design and Testing of Remittance Disclosures



Reputation of the provider



Extra benefits (e.g., free phone call to recipient, rewards)



Customer service



Ease of completing the transaction (e.g., provider stores their information in the
company’s system, requires less paperwork, offers an online option)



Efficient error resolution



Documentation/record keeping



Confirmation provided to sender when funds are received

•

The factors most often identified as the most important in choosing a provider were the
amount of fees charged, convenience of locations for the recipient, and convenience of
locations for the sender. Some participants indicated that the most important factors could
vary depending on the situation. For example, a low fee might be the most important
factor for sending routine remittances, but speed and reliability were most important
when sending money for emergencies.

•

Most participants said they were satisfied with their experience and generally used the
same provider every time they send money.

•



When asked why they did not consider different providers, some participants said it
was because the provider they use has the most convenient location for them or their
recipients. Other reasons included conveniences resulting from using the same
provider, such as having their information already in the provider’s system, an
understanding of that provider’s process, and loyalty rewards (e.g., a free phone call
to the recipient). Some participants noted that because of the importance of these
factors, they were indifferent to the fact that they might get slightly better exchange
rates or fees elsewhere. A few participants said that they were confident their provider
was the least expensive, so there was no need to compare costs.



Some participants commented that they had compared providers when they were
initially searching for a remittance transfer provider, but had eventually decided that a
single provider was best for them.



Participants said that when they send money for an emergency, they do not compare
providers because there is not time to do so.

Only a few participants said that they regularly compare providers when they want to
send money.


Most of those participants who compared providers said they look for the most
favorable fees.



Among participants that generally send money in local currency, most of those
participants who compared providers said that they compare exchange rates between
providers. Some of these participants indicated that they used the internet to
determine the rates at different providers, even if they send the money in person.

Summary of Findings:
Design and Testing of Remittance Disclosures



A few participants said they compared different providers if they were sending an
especially large amount of money. In this case, they said, they might need to find a
different provider because the amount they needed to send exceeded the maximum
allowed by the provider they usually used, because fees might be significantly
different for a large amount of money, or because they were concerned
about security.

Information Received from Providers Before and After In-Person
Transactions
•

Most participants said they did not get any written information before completing an
in-person remittance transaction, but could get information such as fees and exchanges
rates orally, if they asked an agent. In general, they did not think this was a problem.
However, a few participants commented that agents were sometimes reluctant to engage
customers in conversation because they are busy, and several other participants agreed
that this could be a problem.

•

Participants were asked to list what kinds of information they receive from providers
after making an in-person remittance transaction. The most common information
included (in approximate order of frequency):


Name and address of the recipient



Code or confirmation number



Amount of money to be received



Fees



Exchange rate



Name and address of the sender



The date and/or time funds will be available



Amount of money sent



“Fine print” or “rights”



The account number and bank the money is being sent to (for bank transfers only)

•

Most participants said they carefully reviewed some of the information given to them on
a receipt to check for errors, specifically the recipient’s name, the location to which the
money is being sent, and the amount of money the recipient will receive. Most
participants also checked to make sure that their receipt contained a pick-up or
confirmation code. A few participants said they might check the exchange rate and fees.
Very few participants said they read the entire receipt carefully.

•

Most participants who complete remittance transfers in-person said they keep the receipt
until they know the recipient has received the money. A few participants said they save
their receipts for their own records (e.g., for tax purposes).

Summary of Findings:
Design and Testing of Remittance Disclosures

•

Most participants in the English-speaking focus groups said they received written
information in English, regardless of the language they used to communicate with the
provider or its agent. Most of the participants in the Spanish-speaking focus groups said
they received written information in both English and Spanish, but a few participants said
the information was only available in English. A few participants expressed concern that
while getting the information in English was not a problem for them, it could be
challenging for people who have more difficulty understanding written English.

Information Received from Providers Before and After Online Transactions
•

Participants who send money online indicated that before they place the transaction, they
are given a quote that shows the fees they will be charged, the exchange rate, when the
funds will be available, and the amount of funds that will be available to the recipient.
Most of these participants said that they were also given this information after the
transaction, and some of these participants indicated that they also received a
confirmation email with the same information.

•

Participants who send money online generally believed that the information they received
about fees and exchange rates prior to placing the transaction was not an estimate, but an
exact quote. Most of these participants understood that exchange rates change frequently,
and believed that the quote only applied to that specific transaction.

•

Participants who send money online generally keep a record of their transactions for a
longer period of time than those who send money in person. Most of these participants
said that they either save the receipts they receive by email or indicated that the website
itself keeps a history of their transactions.

Reactions to the Idea of Receiving Pre-Transaction Information
•

•

Most participants indicated that receiving additional information prior to completing the
transaction would be useful. Specifically, they would want to know:


The amount to be received



All fees associated with the transaction (including any to be paid by the recipient)



How fees are determined (e.g., based on the amount sent or the speed of delivery)



Exchange rate



Date of availability

Among those participants who wanted to receive more information before their
transactions, approximately half of these participants wanted this information to be
provided in writing.


Most of these participants felt that having the information on paper was important
because if they subsequently had a problem, they would have a record of what they
had been told.

Summary of Findings:
Design and Testing of Remittance Disclosures


•

A few participants said they would use the pre-transaction disclosures they received
to compare providers, and that having it on paper would facilitate this process.

The other half of participants who wanted to receive more pre-transaction information
thought it should be given orally or presented on a screen, like a computer monitor or
those used at check-out registers or to confirm credit card transactions. Some of these
participants felt that requiring providers to give consumers pre-transaction information on
paper unnecessarily complicated a simple process, and were concerned that it could result
in a longer wait time and higher fees. These participants did not feel the benefits of
having pre-transaction information on paper outweighed these potential costs.


A few of these participants said that written pre-transaction information would be
helpful for those who were sending money for the first time, but that it was
unnecessary for those with previous experience.



A few participants said they were concerned that if they received too many papers
they might confuse them, and accidentally discard the paper with their confirmation
code. Several other participants agreed that this was a potential problem.



Most of these participants said they would use the information presented orally or on
a screen to confirm the details of the transaction, such as the recipient’s name or the
amount to be sent.

•

Most participants indicated that even if they received pre-transaction information in
writing, they would still want to receive the same type of receipt they get currently.

•

In most cases, even those participants who wanted more pre-transaction information said
that when sending money they generally already know in advance what fee they will be
charged, and could get additional information from the agent orally if necessary.

•

While most participants indicated that more pre-transaction information would be useful,
there were some who said that it was not necessary in any form. Some of these
participants said that they already had any information they needed from their own
research and experience with remittances, while other participants trusted that the bank or
provider would get the transaction right. Some participants also said that pre-transaction
information they received about fees or exchange rates would be irrelevant to their
decision whether to send the money, because recipients usually needed the funds as soon
as possible for an emergency.

Reactions to the Idea of Posting Information on a Storefront or Online
•

Most participants in the Bethesda focus groups said that no information about remittance
transfers was posted at the providers they use, except for promotional information.
In Los Angeles, some participants indicated that some providers had information about
fees and exchange rates posted on the wall. In both cities, participants who send money
using banks or credit unions said they had never seen any information posted.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

Participants were asked to imagine a storefront posting at a provider that showed how
much money would be available to a recipient if $100 were sent. They were then asked
how useful that information would be to them. Most participants cited limitations or
obstacles to the usefulness of such a posting:


Participants agreed that this information would only be useful to them if the country
to which they wanted to send money was shown on the posting—for example, a
posting showing how much money a recipient in Mexico would receive would not be
useful to someone who wanted to send money to Peru.



One of the most frequent comments was that because exchange rates change often,
and because rates would have to be listed for many different countries, the storefront
posting described would be difficult to keep up-to-date. Several participants
expressed skepticism that providers would be able to display this information
accurately, and said that inaccurate information would be of no use to them.

•

Several participants indicated that the information on this storefront posting would be
useful to them. A few participants said that they would use the posting as a reference
point for comparing providers, and that the storefront posting would save them time
because they would not have to wait in line to talk to an agent to get the information.
Some participants said they would use the storefront posting to decide when to send
money based on fluctuations in the exchange rate, but would be unlikely to use it to
compare different providers.

•

Some participants indicated that the scenario described on the storefront posting was not
the information they sought when sending a remittance transfer. Some participants said it
would be more helpful to see how much money in dollars they would need to send in
order for the recipient to receive a certain amount of local currency, rather than how
much currency would be received if they sent a certain amount in dollars. For example,
they would want to know how many dollars they needed to send for a family member to
receive 100 pesos.

•

Some said that fees sometimes vary by service—for example, they can opt to pay a
higher fee if they want their money to arrive more quickly. They would want this
additional information to be shown, but pointed out that it would increase the
complexity of the posting.



Participants also felt that any posting about fees would need to show fees for different
amounts, otherwise it would be unclear to apply the information to a specific
transaction. For example, some participants incorrectly assumed a linear relationship
between fee and amount sent (e.g., they assumed that the fee on a $300 transaction
would be three times the fee on a $100 transaction). Other participants understood
that this approach might not be accurate—for example, if fees were tiered.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

Regardless of whether or not they felt the storefront posting would be useful, most
participants said that as long as the information shown on the posting was close to what
they expected, they would be unlikely to decide not to follow through with their
intended transaction.

•

Participants who send money online said that the provider typically gives them a realtime exact quote that is specific to the transaction they intend to make. Therefore, these
participants said that an online disclosure containing information similar to that of the
hypothetical storefront posting reflecting model transfer amounts would not be useful.

Dealing with Errors or Problems
•

Most participants reported having had problems with at least one remittance transaction
in the past. However, almost all participants said that their problems had been resolved
fairly quickly, and that the recipient had eventually received their money.


The most frequently cited problem was that the agent or sender had spelled a
recipient’s name incorrectly. Sometimes the sender caught this error when confirming
the transaction information with an agent or reviewing the receipt. In other cases,
participants only became aware of the mistake once the recipient was denied
the money.



A few participants had experiences in which the recipient had been charged
unexpected taxes or fees. Although they found this situation distressing, participants
generally did not blame the provider; they felt it was a problem with the system in the
recipient’s country and not something that could be resolved from the U.S. They did,
however, believe that providers in the U.S. should do a better job of informing them
of any fees or taxes for which the recipient would be responsible.



A few participants were frustrated by delays in the availability of funds to the
recipient. This was especially problematic when the remittance was time-sensitive
and critical, such as for a hospital bill. In these cases, participants complained that
providers either did not explain the reason for the delay, or did not offer senders more
than an apology for the inconvenience.

•

Two participants described situations in which they felt the provider had not satisfactorily
resolved an error. One participant said that the provider had lost his money, and as a
result did not use that provider any more. The other participant felt that she had been
overcharged by her provider; it was unclear whether she still used that provider. A few
other participants said they had changed providers because they were unhappy with the
error resolution process itself, even though the problem was resolved in the end.

•

Most participants indicated that they were aware that the post-transaction receipt
contained information about what to do in the case of an error. However, most
participants also said they had never read this information.

Summary of Findings:
Design and Testing of Remittance Disclosures

Suggestions for Improving the Remittance Process
•

When asked how providers could better provide information to them, participants had the
following suggestions:


Give remittance senders access to a history of their past transactions



Provide confirmation to senders when their funds are received



Make transactions simpler (e.g., by minimizing paperwork, storing information for
senders and past recipients, allowing senders to confirm information on a screen
before completing a transaction)



Contact senders if their funds do not arrive or are not picked up



Print error resolution information and other “fine print” in a larger font

CHAPTER III: DEVELOPMENT OF MODEL DISCLOSURE FORMS
During the next phase of the project, ICF Macro and Board staff worked collaboratively to develop
model disclosure forms. These forms were designed to satisfy the requirements of the Dodd-Frank
Act, and to provide information in a way that would be clear and usable to consumers. The
disclosures were developed in the form of cash register receipts, since the Board expects that at
least some providers would print the disclosures in this format. In order to provide context for
testing participants, the forms described a specific scenario in which a hypothetical consumer was
using a provider called “Global Money Transfers” to send $100 to Mexico, to be received in
Mexican pesos.
Four different types of disclosures were developed for testing:
•

Pre-Transaction Disclosure: This disclosure (referred to as the “P” form) would be
given to consumers before they paid for the transaction. P-1 included the phrase “not a
receipt” at the top of the document, as well as the transfer amount, transfer taxes and fees,
the total transaction amount (i.e., the total amount paid by the sender to the transfer
provider); the exchange rate, the transfer amount expressed in local currency, other taxes
and fees, and the total amount of money (in local currency) that would be available to the
recipient.

•

Post-Transaction Disclosure: This disclosure (referred to as the “T” form 3) would be
given to consumers after they completed the transaction. It included the word “receipt” at
the top of the document, as well as all of the information provided in the P form. In
addition, it provided the name, address, and phone number of the sender; the name and
address of the recipient; the address of the location where the recipient would pick up the
funds; the date the funds would be available; the confirmation code; a statement about the
sender’s error resolution rights; and contact information for the money transfer provider,
the state regulatory agency, and the Consumer Financial Protection Bureau.

•

In some cases, the content of these disclosures was revised throughout the testing process. These
revisions are discussed in detail in Chapter IV.

Summary of Findings:
Design and Testing of Remittance Disclosures

Throughout this report, the disclosure forms are named such that the letter (i.e., P, T, CP, or C)
indicates the type of disclosure, and the number (i.e., 1, 2, or 3) indicates the round in which it was
tested. For example, “CP-2” refers to the combined pre/post-transaction disclosure that was tested
during the second round of interviews. The disclosure forms shown to consumers during each
round of testing are included in this report as Appendix C.
The development of these disclosures was largely based on findings from the focus groups
described in Chapter II. This reliance on “real world” research with consumers is important to
ensure that disclosure forms are useful and understandable to their intended audiences. At the
same time, there are a number of general principles to which ICF Macro’s information
designers try to adhere. Some principles that were especially relevant to the development of
forms for this project include:
•

Use plain language. Jargon and technical language should be avoided whenever
possible, and replaced with words that are more easily understood by consumers. The use
of simple language is particularly important in this context, because consumers that are at
the greatest risk of being taken advantage of are often those with lower literacy levels in
the language in which the disclosure is being provided. While readability metrics (such as
the “grade level” of the writing) can be useful in this respect, the best way to determine
whether language is truly understandable is through direct consumer testing.

•

Prioritize information, and structure disclosures so that the most important
information for consumers is easiest for them to find. Consumers frequently do not
read disclosures carefully; those who look at them often only skim them quickly to look
for a few key pieces of information. Therefore, the information that is most important to
consumers should be located most prominently on the disclosure. In this case, for
example, regulatory agency contact information was placed at the bottom of the forms
since it would be used much less frequently than other transaction information.

•

Group related concepts and figures. Transaction disclosures may attempt to
communicate a great deal of disparate information in a relatively small space.
Consumers are likely to find it easier to absorb and make sense of the information if it
is grouped in a logical way so they do not have to constantly shift their mindset as they
read. On the remittance disclosures, this is done by grouping related information into
three main sections: sender and recipient information, transaction information, and
error resolution information.

•

Keep language and design elements consistent between forms so that information
can be tracked over time. Because there was overlap in the content of pre- and
post-transaction disclosures, both ICF Macro and Board staff anticipated that
consumers would want to use the latter form to confirm that the information they had
been given earlier was accurate. Therefore, any information that was repeated between
the forms was printed in the same order and format on both, to make it easy for
consumers to make this comparison.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

Provide numerical information in a logical order, so that the relationships between
numbers are clear. Most of the disclosures that were developed contained seven
different figures related to money. One concern was that if consumers found it difficult to
distinguish between these figures, they might stop reviewing them carefully—and
therefore might be less aware of the fees and exchange rates that apply. ICF Macro’s
information designers used visual elements to indicate how numbers were related, such as
lines above totals when numbers were being added or subtracted. The information was
also ordered in a logical way—for example, reading top to bottom, all numbers that were
listed after the exchange rate appeared in local currency.

CHAPTER IV: TESTING OF DISCLOSURE FORMS
Methodology
Once the model disclosure forms were drafted, the next phase of the project was to test the extent
to which the disclosure forms communicated information to consumers in a clear and usable way.
To test the forms, ICF Macro conducted in-depth cognitive interviews with a total of 29 consumers
in New York, New York; Atlanta, Georgia; and Bethesda, Maryland. As with the focus groups,
interview participants were recruited by telephone using a screener that was developed
collaboratively by ICF Macro and Board staff. The screening criteria were similar to those used for
the focus groups, with the addition of items that limited the number of participants who only sent
money in dollars and whose primary language was English. The screener for Rounds 2 and 3
included an additional item that excluded anyone who had not sent remittances for personal
purposes. The recruitment screener used for the second and third rounds of interviews is included
as Appendix A; Appendix B provides detailed information about the demographic characteristics
of the interview participants at each site.
The interviews were approximately 60 minutes long and were based on an interview guide
developed collaboratively by ICF Macro and Board staff. Participants were first asked a series of
questions about their experiences sending remittances. They were then given scenarios in which
they completed an imaginary remittance transaction and received one or more of the disclosure
forms being tested. For each scenario, participants were asked to review the disclosure forms
presented and to let the interviewer know if they had any comments or questions. The interviewer
then asked participants specific questions to test their understanding of the information presented in
the form. Participants were also asked attitudinal and preference questions to collect information
about how they felt about the remittance transaction process presented in the scenarios, as well as
the disclosure forms themselves.

Round 1: Interviews in New York, New York (January 2011)
Research Objectives and Forms Tested
ICF Macro conducted 10 cognitive interviews with consumers in New York, New York on January
18 and 19, 2011. The purpose of this round of interviews was to test consumers’ understanding of
the disclosure forms and their reactions to the timing and content of the disclosures. Participants in
this round were asked to imagine two different scenarios in which they made a remittance
transaction and received disclosures. 4
•

In one scenario, participants were given P-1 (a pre-transaction disclosure) after providing
the clerk with transaction information, but before paying. Participants then completed the
imaginary transaction and received T-1 (a post-transaction disclosure).

In order to avoid order effects, the order in which the interviewer presented the scenarios was alternated between participants.
This was done in subsequent rounds of interviews as well.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

In the other scenario, participants were given CP-1 (a combined pre/post-transaction
disclosure) after providing the clerk with transaction information, but before paying.
After completing the imaginary transaction, they were then given C-1, which provided a
confirmation code.

In addition to these four forms, participants were also shown a fifth disclosure (ET-1). ET-1 was
nearly identical to T-1, except that it (a) noted that the exchange rate, transfer amount (in pesos),
other fees and taxes, and total to recipient were estimated amounts; and (b) indicated that the funds
would be “available on or before” a particular date. This language was used to simulate a situation
in which a provider might not be able to provide exact terms for a transaction. ET-1 was not shown
to participants as part of a scenario, but was used at the end of the interview to test participants’
comprehension of the revised text.

Key Interview Findings
Comprehension of Disclosure Forms (P-1, T-1, CP-1, and C-1)

•

All but one of the participants understood from the disclosures the day on which the
money would be available to the recipient. The remaining participant did not see the
“date available” shown on the form, but understood what it meant when it was pointed
out to him. All participants assumed that the money would also be available to the
recipient after the date shown on the form.

•

All participants understood that the provider would charge them a fee of US$10 to send
the money.

•

All participants understood the difference between the “transfer amount” (the amount
being sent to the recipient) and the “total transaction” (the transfer amount plus the fee
being charged to the sender).

•

All participants understood how the exchange rate was applied to the transfer amount to
convert US$100 into pesos for the recipient.

•

Most participants were surprised to see “other fees and taxes” on the disclosure form,
because it was not something they were used to seeing. However, all but two of the
participants correctly assumed that these fees and taxes would be charged on the
receiving end, either by the government or by the facility at which the money would be
picked up. The remaining two participants said they were unsure what the “other fees and
taxes” represented, and would ask the remittance transfer provider.

•

All but one of the participants understood how many pesos the recipient would be able to
pick up. The remaining participant did not notice that “other fees and taxes” would be
subtracted from the transfer amount when it was picked up by the recipient.

Comprehension of Disclosure Form ET-1

•

ET-1 said that the funds would be available “on or before” a given date. Six participants
correctly understood that this meant the funds would definitely be available on or after
the date, and might also be available before that date. The four remaining participants

Summary of Findings:
Design and Testing of Remittance Disclosures

incorrectly interpreted the phrase to mean that the funds would be available anytime
between the day of the transaction and the date on the disclosure, but not after that date.
•

After explaining to participants what was meant by the phrase “on or before,” the
interviewer asked several of them if the phrase “funds available no later than” was
clearer. One participant thought that the new phrase was clearer, but most participants felt
that the two phrases meant the same thing.

•

All participants understood that the word “estimated” on ET-1 meant that the actual
amounts might be different from those shown on the disclosure. Most participants
believed that this information was estimated because it would depend on the exchange
rate at the time the money was picked up.

•

Two participants believed that the transfer provider would likely use the “estimated
exchange rate” to its own advantage by fixing the rate at a time that would be the most
beneficial to the company. As a result, they thought, the amount available to the recipient
would always be lower than what was shown on the disclosure.

Timing of Information

•

Overall, most participants felt it would be useful to receive information prior to
completing a remittance transaction. However, not all participants thought it was
necessary for this information to be given on a piece of paper.


Most participants said it would be useful to review the recipient and pick-up
information prior to completing the transaction, because most transaction errors
resulted from this information being inaccurate. However, half of the participants
expressed some concern over receiving this information on paper, rather than orally or
on a screen. Three of these participants were concerned about the risk of identity theft.
The other two participants said that receiving a “receipt-like” paper disclosure before
the transaction might make them feel obligated to go through with the transaction.



Most participants felt it was important to know the transfer fee prior to completing a
transaction. However, many said it would not be necessary to get this information on a
piece of paper prior to each transaction because they generally already knew what they
would be charged, either because they asked the clerk or because fees did not change.



Most participants felt it would be important to know the exchange rate information in
advance. Two participants said that knowing the exchange rate in advance could help
the sender determine how much money to send in order to ensure that the recipient
would receive a specific amount in local currency. One participant suggested that the
information could be used to compare rates among providers.



Most participants felt that it was unnecessary to include the contact information of the
provider, state regulatory agency, and Consumer Financial Protection Bureau on a
disclosure that was given prior to completing the transaction, as long as they received
this information afterward.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

Two scenarios were described to participants. In one scenario they received P-1
(a pre-transaction disclosure) before the transaction, and T-1 (a post-transaction
disclosure) after the transaction was complete. In the other scenario, participants received
CP-1 (a combined pre/post-transaction disclosure) before the transaction, and C-1
(a notification of confirmation code) after the transaction was complete. Eight of the
participants preferred the first scenario. Many of these participants said it was important
that T-1 could serve as proof that the transaction had occurred, whereas neither CP-1 nor
C-1 could do so. Participants also preferred this scenario because all of the information
needed was available on one piece of paper. As some participants pointed out, C-1 was so
small it could easily get separated from CP-1 (in which case there would be no way of
linking the confirmation code to the transaction) or lost altogether (in which case they
would not have the information needed for the recipient to pick up the money).

•

There were two participants who preferred the scenario with CP-1 and C-1. These
participants felt it was an advantage that C-1 had so little information on it either because
it protected the sender from identity theft or because it protected the transaction from
theft. As the latter explained, if someone found C-1, that person would not be able to
steal the money because the disclosure did not include any other information identifying
the transaction. These participants suggested that the error resolution information should
be included on C-1, rather than CP-1, so they would be free to dispose of CP-1 but still
have the information they needed on C-1 should an error occur.

•

Most participants expected that the information provided on a pre-transaction disclosure
would be accurate for the rest of the day. Most participants thought that if they came back
the following day to complete their transaction, the numbers might be slightly different
because of changes in the exchange rate. A few participants said that if they came back
later to complete the transaction, they would ask the company if the information on the
pre-transaction disclosure was still accurate. One participant said he would expect the
money transfer provider to tell him if any of the information was no longer accurate.

•

When asked how long they would keep the disclosure forms following the transaction,
participants’ responses varied.


P-1 and T-1: Of seven participants who were asked how long they would keep T-1
(the post-transaction disclosure), three participants said that they would keep it until
the recipient picked up the money and four said they would keep it indefinitely
(consistent with their practice of saving receipts). Participants were less likely to say
they would keep P-1; three participants said they would throw it away immediately,
two said they would keep it until the recipient picked up the money, and two
participants indicated they would keep it indefinitely.



CP-1 and C-1: Five of the participants said they would keep CP-1 (combined
pre/post-transaction disclosure) until the recipient picked up the money, four
participants said they would keep it indefinitely (consistent with their practice of
saving receipts), and the remaining participant thought he would throw it away
immediately. Seven of the participants said they would keep C-1 (confirmation code
only) until the recipient picked up the money and the remaining three participants

Summary of Findings:
Design and Testing of Remittance Disclosures

said they would keep it indefinitely along with CP-1 (consistent with their practice of
saving receipts).
Error Resolution Rights

•

Upon reviewing the forms, a few participants commented that they liked the fact that the
error resolution information was presented clearly and concisely. They commented that
the information was much more apparent than on the disclosures they currently receive.

•

Participants were asked what they would do upon learning that the recipient did not
receive the money. Half of the participants indicated that the first thing they would do if
they had a problem would be to go back to where they completed the transaction and talk
to the clerk. The other half said that their first step would be to contact the provider using
the phone number provided on the disclosure.

•

Seven of the participants saw the phone number for the provider in their first review of
the disclosure. Two of the remaining three participants were able to quickly find this
information when prompted by the interviewer. The remaining participant saw the phone
number, but did not know whom he would be contacting if he used it.

•

Participants were then asked what they would do if they had exhausted all their options
with the provider, but the problem had not been resolved. Based on their initial review of
the disclosure form, six participants said that they would contact the state regulatory agency
and/or the Consumer Financial Protection Bureau. Two of the four remaining participants
were able to quickly find contact information for these agencies when prompted by the
interviewer, and understood that they could contact them to get additional help. The two
remaining participants saw the phone numbers, but said they would not contact these
organizations. One of these participants did not believe that state- or federal-level
authorities would get involved in such a specific problem. The other participant felt the
police would be the best option for putting more pressure on the provider.

Subsequent Design Decisions
Based on findings from this round of interviews, several changes were made to the disclosure
forms that were tested in the next round:
•

P-1 and T-1: Because most participants did not have any major difficulties understanding
the information presented in these disclosure forms, no significant changes were made.

•

CP-1 and C-1: Because there was a strong negative response to getting a
post-transaction disclosure listing only the confirmation code, C-1 was dropped from
future rounds of testing and the confirmation code was added to CP-1. Because this
meant that consumers who received the CP form would not receive a separate receipt, the
phrase “not a receipt” was removed from subsequent versions of the CP form.

•

ET-1: Because many participants had difficulty understanding the intent of the phrase
“funds available on or before,” the phrase was changed to “funds available by.”
In addition, to ensure that consumers are aware of their right to cancel remittance

Summary of Findings:
Design and Testing of Remittance Disclosures

transactions, the sentence “You may have a right to cancel this transaction” was added to
the section that includes the money transfer provider’s contact information.

Round 2: Interviews in Atlanta, Georgia (February 2011)
Research Objectives and Forms Tested
ICF Macro conducted 10 cognitive interviews with consumers in Atlanta, Georgia on February 9
and 10, 2011. The purpose of this round of interviews was to test consumers’ understanding of the
revised disclosure forms and their reactions to the timing and content of the disclosures. As with
the first round of testing, participants were shown disclosures for two different scenarios in which
they made a remittance transaction and received disclosures.
•

One scenario was exactly the same as in Round 1: participants were given P-2
(a pre-transaction disclosure) after providing the clerk with transaction information, but
before paying. Participants then completed the imaginary transaction and received T-2
(a post-transaction disclosure).

•

The other scenario was slightly modified from Round 1. After providing the clerk with
transaction information but before paying, participants were given CP-2 (a combined
pre/post-transaction disclosure). Unlike in the first round, however, CP-2 included the
confirmation code. Therefore, participants were not given a second piece of paper after
completing the transaction.

As in the first round, at the end of the interview, participants were again given a final form to
review (ET-2). This form was a modified version of T-2, which differed only in that it (a) noted
that the exchange rate, transfer amount (in pesos), other fees and taxes, and total to recipient were
estimated amounts; (b) indicated that the funds would be “available by” a particular date; and
(c) included the sentence “you may have the right to cancel this transaction.”

Key Interview Findings
Comprehension of Disclosure Forms (P-2, T-2, and CP-2)

As in the first round of testing, most participants did not have difficulty understanding the
information presented in the disclosures.
•

All but one of the participants understood on which day the money would be available to
the recipient. The remaining participant incorrectly assumed, based on prior experience,
that the money would be available right away. All participants believed that the money
would also be available to the recipient after the date shown on the form.

•

All participants understood that the provider would charge them a fee of US$10 to send
the money.

•

Summary of Findings:
Design and Testing of Remittance Disclosures

•

All participants understood how the exchange rate was applied to the transfer amount to
convert US$100 into pesos for the recipient.

•

Seven of the participants understood that “other fees and taxes” were separate from the
“transfer fees and taxes” and would be charged on the receiving end. The remaining three
participants incorrectly assumed that they were only being charged one set of taxes and
fees, and that the “other fees and taxes” shown were the “transfer fees and taxes”
converted into pesos.

•

All participants understood how many pesos the recipient would be able to pick up.

Comprehension of Disclosure Form ET-2

•

ET-2 said that the funds would be “available by” a given date. Only one participant
understood that this meant the funds would be available on or after the given date, and
might also be available before that date. Most participants incorrectly believed the phrase
meant the same thing as the “date available” shown on T-2—that is, that the funds would
be available on or after the given date, but not before. One participant misinterpreted this
phrase to mean that the funds would be available anytime between the date of the
transaction and the given date.

•

Six participants were asked what it would mean if the disclosure indicated that the funds
would be available “no later than” a given date. All six participants assumed this would
mean that the funds would be available anytime between the day of the transaction and
the date on the disclosure, but not after that date.

•

All participants understood that the word “estimated” on ET-2 meant that the actual
amounts might be different from that shown on the form. Eight participants said they
thought any changes in the amounts would be due to fluctuations in the exchange rate.
The remaining two participants believed that the use of the word “estimated” might also
mean that the provider did not know the exact amount of “other fees and taxes” that
would be charged on the receiving end of the transaction.

Timing of Information

•

As in the first round of testing, most participants felt it could be useful to receive
information prior to completing a remittance transaction. Most participants said they
would use information on a pre-transaction disclosure to review or confirm information
(e.g., recipient information, fees, amount to the recipient) prior to completing the
transaction. Two participants noted that they could use the fee and exchange rate on a
pre-transaction disclosure to determine the amount they needed to send to ensure that a
recipient would get a specific amount of local currency.

•

Most participants did not mention a preference for how pre-transaction information
should be provided. However, two participants said they would prefer to get the
information on paper, one preferred oral confirmation, and another preferred to see the
information on a screen. One of the participants who preferred paper said it would be

Summary of Findings:
Design and Testing of Remittance Disclosures

easier for senders for whom English is not the primary language they speak; the other felt
that a pre-transaction disclosure on paper could better protect against fraudulent practices.
•

Two scenarios were described to participants. The first scenario was the same as in
Round 1—participants received P-2 (a pre-transaction disclosure) before the transaction,
and T-2 (a post-transaction disclosure) after the transaction was complete. In the other
scenario, participants received CP-2 (a combined pre/post-transaction disclosure with the
confirmation code) before the transaction, but no additional disclosures after the transaction
was complete. Four of the participants said they preferred the scenario in which they were
given CP-2 (combined pre/post-transaction disclosure) before completing the transaction,
rather than separate pre- and post-transaction disclosures. Two of these participants
commented that a separate pre-transaction disclosure would be a waste of paper, while
another said that he would prefer to have all of the transaction information prior to
completing the transaction. All four participants indicated that it would not bother them if
they did not receive a disclosure after completing the transaction.

•

Six of the participants said they preferred the scenario in which they were given P-2
(pre-transaction disclosure) and then T-2 (post-transaction disclosure). Half of these
participants felt this way because they found it unsettling to be given a receipt-like form
with a confirmation code prior to completing the transaction (as in the CP-2 scenario).
Two of the participants were concerned that CP-2 would not serve as proof that the
transaction occurred. The remaining participant was concerned that CP-2, because it was
more comprehensive, would represent a commitment to complete the transaction. He
worried that if he wanted to change anything after seeing CP-2, the provider might charge
him money to do so.

•

On the second day of testing, all three participants who expressed a preference for the
P-2/T-2 scenario were asked how they would feel about CP-2 if it was stamped “paid”
following the transaction. Two of the three participants said this would resolve their
concern about CP-2, because the stamp would show that the transaction had been
completed. The remaining participant did not believe this would be sufficient for CP-2 to
serve as proof of the transaction because a “paid” stamp was easily faked.

•

Most participants expected that the information provided on a pre-transaction disclosure
would be accurate for the rest of the day, but could be slightly different the following day
due to fluctuations in the exchange rate. Two of these participants commented that it
would be the provider’s responsibility to let them know if any of the information had
changed. One participant incorrectly thought the terms would be accurate for 180 days
because of the text on the disclosure stating that “if you have any problems or questions
about this transaction, contact us within 180 days.”

•

Of the seven participants who were asked how long they would keep the disclosures,
three participants said they would keep T-2 (post-transaction disclosure) or CP-2
(combined pre/post-transaction disclosure) until the recipient picked up the money, and
four participants said they would keep the disclosures for a longer period of time or
indefinitely (consistent with their practice of saving receipts). Participants were less
likely to say they would keep P-2; four participants said they would throw it away

Summary of Findings:
Design and Testing of Remittance Disclosures

immediately, and three participants said they would keep it for a longer period of time or
indefinitely.
Error Resolution Rights

•

As in the first round, a few participants commented that they appreciated how concisely
and clearly the error resolution information was presented on the disclosures.

•

Participants were asked what they would do upon learning that the recipient did not
receive the money. All but one of the participants said they would contact the provider
directly using the phone number given on the disclosure form. The remaining participant
did not see the provider’s contact information on the form, and said he would call the
state regulatory agency (which he found on the form) to get that information.

•

Cancellation Rights

•

When presented with the scenarios, participants were asked if they believed they could
cancel the transaction after sending the money. 5 Four participants believed that once the
transaction had been completed, they would be unable to cancel it. Six participants
believed that they would be able to cancel the transaction, as long as the recipient had not
picked up the money. Two of these participants expected they would be charged an
additional fee for cancelling the transaction.

•

After reviewing ET-2, which did include a sentence stating that they “may have the right
to cancel this transaction,” participants were again asked if they thought they could
cancel. Eight participants indicated that they would be able to cancel, while the remaining
two were unsure.

•

When asked what would be returned to them if they cancelled the transaction, eight
participants believed the provider would return the money they sent, but not the transfer
fee they had paid. The remaining two participants thought that the provider would return
the transfer fee as well. Of the two participants who, prior to reviewing ET-2, thought
they would be charged an additional fee for cancelling, one no longer thought so while
the other was unsure.

•

When asked how long they would have to cancel the transaction, participants’ responses
varied. Three participants believed the cancellation period would be indefinite, as long as
the recipient had not picked up the money. Other participants assumed that there would

Forms P-2, T-2, and CP-2 did not include any information about consumers’ right to cancel.

Summary of Findings:
Design and Testing of Remittance Disclosures

be a limit to how long they could cancel; responses included: a few minutes, a few days,
a week, 30 days, or 180 days.

Subsequent Design Decisions
Based on findings from this round of interviews, several changes were made to the disclosure
forms that were tested in the next round:
•

Cancellation Rights: Because participants’ assumptions about their cancellation rights
varied widely, the sentence “You may have the right to cancel this transaction within 24
hours of payment” was added to all forms.

•

P-2, T-2, and CP-2: Because most participants did not have any major difficulties
understanding the information presented in these disclosure forms, no other significant
changes were made.

•

ET-2: Because many participants had difficulty understanding the intent of the phrase
“funds available by,” the phrase was changed to “date available” (i.e., the same phrase
used to describe the date that funds would be available on other forms). However, the
phrase “may be available sooner” was added to indicate that the funds might be available
before the date shown.

Round 3: Interviews in Bethesda, Maryland (March 2011)
Research Objectives and Forms Tested
ICF Macro conducted nine cognitive interviews with consumers in Bethesda, Maryland on
March 2 and 3, 2011. Like previous rounds of interviews, the purpose of this round was to test
consumers’ understanding of revised disclosure forms and their reactions to the timing and
content of the disclosures. As with the first two rounds, participants were asked to imagine two
different scenarios in which they made a remittance transaction and received disclosures.
The scenarios for this round were exactly the same as the previous round:
•

In one scenario, participants were given P-3 (a pre-transaction disclosure) after providing
the clerk with transaction information, but before paying. Participants then completed the
imaginary transaction and received T-3 (a post-transaction disclosure).

•

In the other scenario, participants were only given one piece of paper, CP-3 (combined
pre/post-transaction disclosure), which included the confirmation code. They were given
CP-3 after providing the clerk with transaction information, but before paying for
the transaction.

As in the first two rounds, participants were given a final disclosure form to review (ET-3). Again,
this disclosure was a modified version of T-3, which differed only in that it (a) noted that the
exchange rate, transfer amount (in pesos), other fees and taxes, and total to recipient were
estimated amounts; and (b) indicated that the funds “may be available sooner” than the date given.

Summary of Findings:
Design and Testing of Remittance Disclosures

The forms that were tested on the two days of interviews differed slightly in the wording they used
to describe the error resolution process and the right to cancel. The forms used on the second day
are referred to as “3b” in this report (e.g., P-3 on the first day vs. P-3b on the second day).
Unless mentioned below, the differences between these forms had no impact on participants’
understanding of or reaction to the forms.

Key Interview Findings
Comprehension of Disclosure Forms (P-3, T-3, and CP-3)

As in the first two rounds of testing, most participants did not have difficulty understanding the
information presented in the disclosures.
•

All participants understood that the money would be available to the recipient on or after
the date on the disclosure, but not before.

•

All participants understood that the provider would charge them a fee of US$10 to send
the money.

•

All participants on the first day of testing 6 understood the difference between the
“transfer amount” (the amount being sent to the recipient) and the “total transaction”
(the transfer amount plus the fee being charged to the sender).

•

All but one of the participants understood how the exchange rate was applied to the
transfer amount to convert US$100 into pesos for the recipient. The remaining participant
mistakenly believed that the “exchange rate” shown on the disclosure was a fee charged
for changing dollars into pesos.

•

All but two of the participants understood that “other fees and taxes” were separate from
the “transfer fees and taxes” and would be charged on the receiving end. The remaining
two participants believed the “other fees and taxes” shown were the “transfer fees and
taxes” converted into pesos. One of these participants later realized and corrected his error.

•

All but two of the participants understood how many pesos the recipient would be able
to pick up. The remaining two participants indicated that the recipient would be able to
pick up the “transfer amount” shown on the form; they failed to subtract the “other fees
and taxes.”

Comprehension of Disclosure Form ET-3

•

ET-3 indicated the “date available” for the funds, but also that they “may be available
sooner.” In contrast to the previous rounds of testing, all of the participants correctly
understood the intent of this section of this disclosure—that the funds would be available
on or after the given date, and might be available before that date.

Participants on the second day of testing were not asked this question, because the phrase “total transaction” did not appear on
the forms used on the second day. Instead, the forms said “total.”

Summary of Findings:
Design and Testing of Remittance Disclosures

•

All participants understood that the word “estimated” on ET-3 meant that the actual
amounts might be different from that shown on the form. All participants believed this
would be due to fluctuations in the exchange rate, and one participant added that it could
also be because the company was new and did not fully understand the money transfer
process. While a few participants were skeptical that the recipient would ever get more
than was shown on the disclosure, most participants agreed that the amount could be
more or less.

Timing of Information

•

As in the previous rounds of testing, most participants felt it could be useful to receive
information from a provider prior to completing a remittance transaction. Most
participants said information on a pre-transaction disclosure could be used to review or
confirm the details of the transaction (e.g., recipient information, fees, amount to the
recipient) prior to completing the transaction. One participant noted that knowing the
exchange rate in advance could help someone determine the amount they needed to send
in order to ensure that a recipient would get a specific amount of local currency.

•

Most participants did not have a strong preference for how pre-transaction information
should be presented. One participant felt that providing information in written form was a
“waste of paper,” because the information could be provided orally instead. However,
another participant said that someone for whom English was not a primary language, she
would prefer to receive the information on paper because it would be easier for her to
understand. A few participants suggested that having the information on paper would
only be useful if someone was unfamiliar with the process and fees, such as the first time
they make a transaction.

•

The same two scenarios were presented to participants as were used in Round 2.
In one scenario, participants received P-3 (a pre-transaction disclosure) before the
transaction, and T-3 (a post-transaction disclosure) after the transaction was complete.
In the other scenario, participants received CP-3 (a combined pre/post-transaction
disclosure with the confirmation code) before the transaction, but no additional
disclosures after the transaction was complete. Half of the participants said they preferred
the scenario in which they received CP-3 before completing the transaction.
These participants preferred this scenario because it provided the opportunity to review
all of the information (including the recipient’s name and address) prior to completing the
transaction. They also felt that it was simpler to have only one piece of paper. All of these
participants indicated that it would not concern them if they did not receive a second
disclosure after completing the transaction.

•

The other half of participants said they preferred the scenario in which they were given
P-3 (pre-transaction disclosure) and then T-3 (post-transaction disclosure). Some of these
participants were concerned that CP-3 would not represent proof that the transaction had
occurred, a concern brought up by participants in other rounds as well. Others felt that
CP-3 provided too much information before the transaction, and might be potentially
distracting. They preferred to only receive the information shown on P-3 prior to the
transaction, and to get the rest of the information after the transaction.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

Those participants who expressed a preference for the P-3/T-3 scenario were asked how
they would feel about CP-3 if it received some kind of stamp (e.g., “paid” or
machine-stamped time and date) following the transaction. These participants felt that this
would be an improvement, but still preferred getting separate pre- and post-transactions.

•

In contrast to previous rounds, participants were divided as to how long they thought the
information provided on a pre-transaction disclosure would be accurate. Three participants
thought the same as most participants in previous rounds—that the information would be
accurate for the rest of the day, but could be different the following day due to fluctuations
in the exchange rate. About half of the participants believed that the information on the pretransaction disclosure might be different after only an hour. One participant thought it
would be unlikely for the information to change even after a day.

•

Participants were also asked how long they would keep the disclosures. As with previous
rounds, their responses were generally consistent with how they currently handle
remittance receipts. Six of the participants said they would keep T-3 (post-transaction
disclosure) or CP-3 (combined pre/post-transaction disclosure) until the recipient picked
up the money, and the remaining three participants said they would keep the disclosures
for a longer period of time or indefinitely. Participants were less likely to say they would
keep P-3—seven participants said they would discard it immediately, one participant
indicated that he would throw it away once the recipient received the money, and the
remaining participant said she would file it with other receipts for a longer period of time.

Error Resolution Rights

•

Participants were asked what they would do upon learning that the intended recipient did
not receive the money. All participants said they would contact the provider directly
using the phone number given on the disclosure form. However, one of these participants
added that he would likely try to contact the specific branch where the transaction
occurred, rather than use the main number provided on the disclosure.

•

Participants were then asked what they would do if they had exhausted all of their options
with the provider, but the problem had not been resolved. Based on their initial review of
the disclosure forms, all but two of the participants said they would contact the state
regulatory agency and/or the Consumer Financial Protection Bureau. The remaining
participants initially said they would contact the Better Business Bureau or a lawyer.
Once prompted by the interviewer, both of these participants were able to locate the
relevant information on the form and understood they could contact these agencies to get
additional help.

Cancellation Rights

•

All participants understood, based on the disclosure forms, that they had the right to
cancel the transaction within 24 hours of payment. All but one said they would not be
able to cancel the transaction if the money had already been picked up, even if it was
within the 24-hour window. The remaining participant thought it might be possible for
someone to “do a scam” and cancel the transaction after the money had been picked up.

Summary of Findings:
Design and Testing of Remittance Disclosures

•

When asked if they could cancel the transaction after 24 hours, most participants said
they were unsure but would contact the provider to find out. Two participants did not
believe it would be possible to cancel the transaction after 24 hours, even if the money
had not been picked up.

•

Participants were also asked if they believed they would get the transfer fee back if
they cancelled the transaction. Their responses differed depending on the forms they
were shown.


T-3 and CP-3 (Day 1): These forms included the sentence “You may have the right
to cancel this transaction within 24 hours of payment.” None of the participants who
saw these forms believed they would be refunded the transfer fee if they cancelled
the transaction.



T-3b and CP-3b (Day 2): On these forms the sentence was revised to say “You may
have the right to cancel for a full refund within 24 hours of payment.” Three of the
four participants who saw these forms believed that they would be refunded the
transfer fee if they cancelled the transaction.

Subsequent Design Decisions
Because comprehension of the forms in this round was very high, only a few changes were made
to the disclosures following this round of testing.
•

ET-3 was significantly more successful than ET-1 or ET-2 at explaining that funds would
be available on or after the date shown and might also be available before that date.
Therefore, the wording of ET-3 (i.e., that funds “may be available sooner”) was used in
the proposed model forms that are expected to be published by the Board in spring 2011.

•

Participants on the second day were significantly more likely to understand that if they
cancelled their transaction, their transfer fee would be refunded to them. Therefore, the
wording used to describe the right to a refund on the second day (i.e., “the right to cancel
for a full refund”) was used as a basis for the Board’s proposed model forms.

CHAPTER V: CONCLUSION
This report summarizes work conducted by ICF Macro from November 2010 through April 2011
in support of the Board’s efforts to revise rules pertaining to remittance transaction disclosures.
ICF Macro conducted this work in three phases: (1) conducting exploratory focus groups to learn
about how consumers make decisions about sending remittances and what information that is
useful to them in this context; (2) designing model disclosures that are clear and understandable to
consumers; and (3) conducting cognitive interviews to test consumers’ comprehension of and
reaction to the information presented in the disclosures.
The research findings described in this report will be an important source of data for the Board as it
prepares its proposed rules related to remittances. The disclosures developed through the iterative
testing discussed herein will be used as a basis for the Board’s proposed model forms ensure that
its new regulations will lead to the provision of disclosures that are easy for consumers to
understand and use.

APPENDIX A:
SAMPLE RECRUITMENT SCREENERS

Focus Group
Recruitment Screener

Participant Screener for Federal Reserve Board Focus Groups
Bethesda, MD
December 2, 2010
General Information and Recruiting Specifications
 Focus groups will be held at 6:00pm and 8:00pm
 A total of 14 recruits for each group.
 All participants must be fluent in English.
 INTERVIEWERS: Ask all participants to bring their reading glasses if necessary.

Recruiting Script
A research company will be conducting a series of focus groups in your area to learn more about
how people make financial decisions. I would like to ask you a few questions to determine if you
qualify to participate in these groups.
Q1: Have you ever worked in the financial industry, like for a bank, credit union, mortgage
lender, or money transfer service?
 Yes  Thank respondent and end call.
 No  Continue
Q2: Have you participated in any other focus groups in the past 6 months?
 Yes  Thank respondent and end call.
 No  Continue
Q3: Have you ever sent money to a person or a company in another country using a bank, credit
union, or money transfer service?
 Yes  Continue
 No  Thank respondent and end call.
Q4: How often do you send money to another country?





Less than once a year  Thank respondent and end call.
1 to 3 times a year  Continue
Every 2 or 3 months  Continue
Once a month or more  Continue

Q5: What kind of company have you used to send money to other countries? (select all
that apply)
 a) Have you sent money using a money transfer service, like one you might find in a
convenience or grocery store, or on the internet? (If respondent doesn’t understand
question, provide Western Union or Moneygram as examples of money transfer
services.) (at least 6 recruits must say “yes”)
 b) Have you sent money using a bank or credit union? (at least 5 recruits must
say “yes”)
If participant answers “No” to both parts of Q5, they do not qualify--thank them and end call.
Q6: How have you sent money to other countries? (select all that apply)






a) Have you placed an order in person?
b) Have you placed an order using the internet? (at least 3 recruits must say “yes”)
c) Have you placed an order by telephone?
d) Have you sent money by mail?
e) Have you sent money in some other way? If so, specify: _____________________.

Q7: ARTICULATION: Do you always send money using the same company? If yes, why?
If no, why do you use different companies? [and/or ask: “Do you always send money using
the same method? If yes, why? If no, why have you used different methods?”]
 If respondent gives thoughtful, articulate answer  Continue
 If respondent does not give a thoughtful, articulate answer  Thank respondent and
end call.
Q8: What is the average amount of money that you
usually send?
a)
b)
c)
d)

Less than $100
$100 to $250
$250 to $500
More than $500

Q9: For how many years have you lived in the
United States?
a)
b)
c)

No quotas.

0 to 5 years
5 to 10 years
More than 10 years

 At least 5 participants should
answer (a) or (b).
 At least 5 participants should
answer (c).

Q10: To what country do you usually send money?
Record country:
______________________________

 No more than 6 participants
should be sending money to a
Latin American or Caribbean
country (including Mexico).
 No more than 6 participants
should be sending money to an
Asian country.
 No more than 4 participants
should be sending money to the
same country.

Q11: What is the highest level that you reached
in school?
a)
b)
c)

High school diploma or less
Some college work
College graduate

Q12: What is your age?
a)
b)
c)

 No more than 5 participants
should answer (c)

18-30 years
31-50 years
50+ years

 No more than 6 participants
should answer (a)
 No more than 6 participants
should answer (b)
 No more than 6 participants
should answer (c)

In-Depth Interview
Recruitment Screener

Participant Screener for Federal Reserve Board In-Depth Interviews
Bethesda, MD
March 2 and 3, 2011
General Information and Recruiting Specifications
 In-depth interviews will be held on [date and time]
 A total of 12 recruits – 6 per day: 5 for interviews and one floater for half the day.
 All quotas listed in the screener apply to the 12 recruits
 All participants must be fluent in English.
 INTERVIEWERS: Ask all participants to bring their reading glasses if necessary.

Recruiting Script
A research company will be conducting a series of in-depth interviews in your area to learn more
about how people make financial decisions. I would like to ask you a few questions to determine
if you qualify to participate in these interviews.
Q1: Have you ever worked in the financial industry, like for a bank, credit union, mortgage
lender, or money transfer service? (If respondent doesn’t understand question, provide
Western Union or Moneygram as examples of money transfer services.)
 Yes  Thank respondent and end call.
 No  Continue
Q2: Have you participated in any focus groups or in-depth interviews in the past 6 months?
 Yes  Thank respondent and end call.
 No  Continue
Q3: Have you ever sent money to a person or a company in another country using a bank, credit
union, or money transfer service?
 Yes  Continue
 No  Thank respondent and end call.
Q4: When you sent money to a person or a company in another country, have you done so for
personal reasons, such as to send money to a friend or relative?
 Yes  Continue
 No (e.g., has only sent money on behalf of employer)  Thank respondent and
end call.

Q5: How often do you send money to another country?





Less than once a year  Thank respondent and end call.
1 to 3 times a year  Continue
Every 2 or 3 months  Continue
Once a month or more  Continue

Q6: What kind of company have you used to send money to other countries? (select all
that apply)
 a) Have you sent money using a money transfer service, like one you might find in a
convenience or grocery store, or on the internet? (at least 5 recruits must say “yes”)
 b) Have you sent money using a bank or credit union? (at least 4 recruits must
say “yes”)
If participant answers “No” to both parts of Q6, they do not qualify--thank them and end call.
Q7: How have you sent money to other countries? (select all that apply)






a) Have you placed an order in person?
b) Have you placed an order using the internet?
c) Have you placed an order by telephone?
d) Have you sent money by mail?
e) Have you sent money in some other way? If so, specify: _____________________.

If participant answers “No” to Q7a, they do not qualify – thank them and end call.
Q8: ARTICULATION: Do you always send money using the same company? If yes, why?
If no, why do you use different companies? [and/or ask: “Do you always send money using
the same method? If yes, why? If no, why have you used different methods?”]
 If respondent gives thoughtful, articulate answer  Continue
 If respondent does not give a thoughtful, articulate answer  Thank respondent
and end call.
Q9: What is the average amount of money that you
usually send?
a)
b)
c)
d)

Less than $100
$100 to $250
$250 to $500
More than $500

 At least 4 participants should
answer (a) or (b).
 At least 4 participants should
answer (c) or (d).

Q10: When you send money, does the recipient usually
receive U.S. dollars or local currency?

 At least 8 participants should
answer (b).

a) U.S. dollars
b) Local currency
Q11: For how many years have you lived in the
United States?
a) 0 to 5 years
b) 5 to 10 years
c) More than 10 years
Q12: Is English the primary language you speak
at home?

 At least 5 participants should
answer (a).
 No more than 2 participants
should answer (c).
 At least 10 participants must say
“No.”

 Yes
 No
Q13: To what country do you usually send money?
Record country:
______________________________

 At least 3 participants should send
money to Mexico.
 No more than 7 participants
should be sending money to a
Latin American or Caribbean
country (including Mexico).
 At least 3 participants should be
sending money to an Asian
country.
 No more than 4 participants
should be sending money to the
same country.
Note: For the purposes of screening,
Puerto Rico does not count as
another country. Participants who
only send money to Puerto Rico
should not be recruited.

Q14: What is the highest level that you reached
in school?
a) High school diploma or less
b) Some college work
c) College graduate

 No more than 3 participants
should answer (c)

Q15: What is your age?
a) 18-30 years
b) 31-50 years
c) 50+ years

 No more than 5 participants
should answer (a)
 No more than 5 participants
should answer (b)
 No more than 5 participants
should answer (c)

APPENDIX B:
PARTICIPANT DEMOGRAPHIC
INFORMATION

Bethesda, MD
Dec. 2 and 7, 2010
Focus Groups

Los Angeles, CA
Dec. 14, 2010
Focus Groups

New York, NY
Jan. 18-19, 2011
Interviews

Atlanta, GA
Feb. 9-10, 2011
Interviews

Bethesda, MD
March 2-3, 2011
Interviews

Total

17
11
28

10
17
27

5
5
10

5
4
9

42 (50%)
42 (50%)
84 (100%)

8
12
7
27

2
5
3
10

4
5
1
10

4
4
1
9

27 (32%)
36 (43%)
21 (25%)
84 (100%)

9
8
10
27

1
5
4
10

3
4
3
10

0
6
3
9

18 (21%)
35 (42%)
31 (37%)
84 (100%)

4
6
17
27

2
5
3
10

0
4
5
9

11 (13%)
26 (31%)
47 (56%)
84 (100%)

3
7
10

3
6
9

9 (31%)
20 (69%)
29 (100%)

Gender
Male
Female
Total
Age
18-30
9
30-50
10
50+
9
Total
28
Highest Level of Education
High School
5
Some college
12
College graduate
11
Total
28
Time Lived in the United States
0-5 years
3
5-10 years
6
10+ years
19
Total
28
English Spoken as Primary Language at Home 1
Yes
No
Total
-

This question was not asked of participants in the focus groups.

Bethesda, MD
Dec. 2 and 7, 2010
Focus Groups
Frequency of Sending Remittances
1-3 times per year
13
Every 2-3 months
4
At least once per month
11
Total
28
Currency Usually Sent to Recipient
Dollars
16
Local Currency
10
Total
26 2
Sent Money through Money Transfer Service
Yes
27
No
1
Total
28
Sent Money through Bank or Credit Union
Yes
14
No
14
Total
28

Los Angeles, CA
Dec. 14, 2010
Focus Groups

New York, NY
Jan. 18-19, 2011
Interviews

Atlanta, GA
Feb. 9-10, 2011
Interviews

Bethesda, MD
March 2-3, 2011
Interviews

Total

5
10
12
27

5
2
3
10

2
3
5
10

6
1
2
9

31 (37%)
20 (24%)
33 (39%)
84 (100%)

9
17
262

3
7
10

4
5
9

35 (43%)
46 (57%)
81 (100%)

23
4
27

8
2
10

9
1
10

9
0
9

76 (90%)
8 (10%)
84 (100%)

12
15
27

5
5
10

2
7
9

38 (45%)
46 (55%)
84 (100%)

Not all focus group participants responded to this question.

APPENDIX C:
MODEL DISCLOSURES USED IN TESTING

Round 1:
New York, NY
January 18-19, 2011
Pre-Transaction Disclosure (P-1)
Post-Transaction Disclosure (T-1)
Combined Pre/Post-Transaction Disclosure (CP-1)
Confirmation Code Disclosure (C-1)
Estimated Post-Transaction Disclosure (ET-1)

Global Money Transfers
123 Eastern Avenue
New York, NY 12345
Today’s Date:

1/18/2011

NOT A RECEIPT
Transfer Amount:
Transfer Fee:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00
US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

P-1

Global Money Transfers
123 Eastern Avenue
New York, NY 12345
Today’s Date:

1/18/2011

RECEIPT
SENDER:
Pat Jones
123 Broadway Avenue
New York, NY 12345
212-123-4567
RECIPIENT:
Carlos Gomez
106 Lorenzo Boturini
Mexico City
Mexico
PICK-UP LOCATION:
Global Money Transfers
65 San Antonio Abad
Mexico City
Mexico
Date Available:

1/19/2011

Confirmation Code:

ABC 123 DEF 456

Transfer Amount:
Transfer Fee:
Total Transaction:

$100.00
$10.00
$110.00

Exchange Rate:

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

If you have any problems or questions
about this transaction, contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can also contact us
for an explanation of your rights.
For questions or complaints about
Global Money Transfers, contact:
New York State Banking Department
877-226-5697
www.banking.state.ny.us/csci.htm
Bureau of Consumer Financial
Protection
800-555-9999
www.cfpb.gov

T-1

Global Money Transfers
123 Eastern Avenue
New York, NY 12345
Today’s Date:

1/18/2011

NOT A RECEIPT
SENDER:
Pat Jones
123 Broadway Avenue
New York, NY 12345
212-123-4567
RECIPIENT:
Carlos Gomez
106 Lorenzo Boturini
Mexico City
Mexico
PICK-UP LOCATION:
Global Money Transfers
65 San Antonio Abad
Mexico City
Mexico
Date Available:

1/19/2011

Transfer Amount:
Transfer Fee:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00
US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

CP-1

Global Money Transfers
123 Eastern Avenue
New York, NY 12345
Today’s Date:

1/18/2011

CONFIRMATION CODE
ABC 123 DEF 456

C-1

Global Money Transfers
123 Eastern Avenue
New York, NY 12345
Today’s Date:

1/18/2011

ABC 123 DEF 456

Funds Available On or Before:
1/28/2011
Transfer Amount:
Transfer Fee:
Total Transaction:

$100.00
$10.00
$110.00

Estimated Exchange Rate:
US$1.00 = 12.27 MXN
Estimated Transfer Amount:
1,227.00 MXN
Other Estimated Fees and Taxes:
-40.00 MXN
Estimated Total to Recipient:
1,187.00 MXN
If you have any problems or questions
about this transaction, contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can also contact us
for an explanation of your rights.
For questions or complaints about
Global Money Transfers, contact:
New York State Banking Department
877-226-5697
www.banking.state.ny.us/csci.htm
Bureau of Consumer Financial
Protection
800-555-9999
www.cfpb.gov

ET-1

Round 2:
Atlanta, GA
February 9-10, 2011
Pre-Transaction Disclosure (P-2)
Post-Transaction Disclosure (T-2)
Combined Pre/Post-Transaction Disclosure (CP-2)
Estimated Post-Transaction Disclosure (ET-2)

Global Money Transfers
1350 Spring St NW
Atlanta, GA 30309
Today’s Date:

2/09/2011

NOT A RECEIPT
Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

P-2

Global Money Transfers
1350 Spring St NW
Atlanta, GA 30309
Today’s Date:

2/09/2011

RECEIPT
SENDER:
Pat Jones
1819 Peachtree Rd NE
Atlanta, GA 30309
404-123-4567
RECIPIENT:
Carlos Gomez
106 Lorenzo Boturini
Mexico City
Mexico
PICK-UP LOCATION:
Global Money Transfers
65 San Antonio Abad
Mexico City
Mexico
Confirmation Code:

ABC 123 DEF 456

Date Available:

2/10/2011

Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

If you have any problems or questions
about this transaction, contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can also contact us
for an explanation of your rights.
For questions or complaints about
Global Money Transfers, contact:
Georgia Department of Banking and
Finance
770-986-1633
www.gadbf.org
Bureau of Consumer Financial
Protection
800-555-9999
www.cfpb.gov

T-2

Global Money Transfers
1350 Spring St NW
Atlanta, GA 30309
Today’s Date:

2/09/2011

SENDER:
Pat Jones
1819 Peachtree Rd NE
Atlanta, GA 30309
404-123-4567
RECIPIENT:
Carlos Gomez
106 Lorenzo Boturini
Mexico City
Mexico
PICK-UP LOCATION:
Global Money Transfers
65 San Antonio Abad
Mexico City
Mexico
Confirmation Code:

ABC 123 DEF 456

Date Available:

2/10/2011

Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

If you have any problems or questions
about this transaction, contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can also contact us
for an explanation of your rights.
For questions or complaints about
Global Money Transfers, contact:
Georgia Department of Banking and
Finance
770-986-1633
www.gadbf.org
Bureau of Consumer Financial
Protection
800-555-9999
www.cfpb.gov

CP-2

Global Money Transfers
1350 Spring St NW
Atlanta, GA 30309
Today’s Date:

2/09/2011

ABC 123 DEF 456

Funds Available By:
2/20/2011
Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:

$100.00
$10.00
$110.00

Estimated Exchange Rate:
US$1.00 = 12.27 MXN
Estimated Transfer Amount:
1,227.00 MXN
Other Estimated Fees and Taxes:
-40.00 MXN
Estimated Total to Recipient:
1,187.00 MXN
If you have any problems or questions
about this transaction, contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can also contact us
for an explanation of your rights.
You may have the right to cancel this
transaction.
For questions or complaints about
Global Money Transfers, contact:
Georgia Department of Banking and
Finance
770-986-1633
www.gadbf.org
Bureau of Consumer Financial
Protection
800-555-9999
www.cfpb.gov
ET-2

Round 3, Day 1:
Bethesda, MD
March 2, 2011
Pre-Transaction Disclosure (P-3)
Post-Transaction Disclosure (T-3)
Combined Pre/Post-Transaction Disclosure (CP-3)
Estimated Post-Transaction Disclosure (ET-3)

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/02/2011

NOT A RECEIPT
Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

P-3

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/02/2011

RECEIPT
SENDER:
Pat Jones
100 Hallowell Street
Bethesda, MD 20810
301-555-1212
RECIPIENT:
Carlos Gomez
106 Lorenzo Boturini
Mexico City
Mexico
PICK-UP LOCATION:
Global Money Transfers
65 San Antonio Abad
Mexico City
Mexico
Confirmation Code:

ABC 123 DEF 456

Date Available:

3/03/2011

Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

If you have any problems or questions
about this transaction, contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can also contact us
for a written explanation of your
rights. You may have the right to
cancel this transaction within 24
hours of payment.
For questions or complaints about
Global Money Transfers, contact:
Maryland Office of the Commissioner
of Financial Regulation
410-230-6077
www.dllr.state.md.us/finance/
Consumer Financial Protection Bureau
800-555-9999
www.cfpb.gov

T-3

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/02/2011

SENDER:
Pat Jones
100 Hallowell Street
Bethesda, MD 20810
301-555-1212
RECIPIENT:
Carlos Gomez
106 Lorenzo Boturini
Mexico City
Mexico
PICK-UP LOCATION:
Global Money Transfers
65 San Antonio Abad
Mexico City
Mexico
Confirmation Code:

ABC 123 DEF 456

Date Available:

3/03/2011

Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

CP-3

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/02/2011

ABC 123 DEF 456
3/12/2011
(May be available
sooner)

Transfer Amount:
Transfer Fees and Taxes:
Total Transaction:

$100.00
$10.00
$110.00

Estimated Exchange Rate:
US$1.00 = 12.27 MXN
Estimated Transfer Amount:
1,227.00 MXN
Other Estimated Fees and Taxes:
-40.00 MXN
Estimated Total to Recipient:
1,187.00 MXN
If you have any problems or questions
about this transaction, contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can also contact us
for a written explanation of your
rights. You may have the right to
cancel this transaction within 24
hours of payment.
For questions or complaints about
Global Money Transfers, contact:
Maryland Office of the Commissioner
of Financial Regulation
410-230-6077
www.dllr.state.md.us/finance/
Consumer Financial Protection Bureau
800-555-9999
www.cfpb.gov
ET-3

Round 3, Day 2:
Bethesda, MD
March 3, 2011
Pre-Transaction Disclosure (P-3b)
Post-Transaction Disclosure (T-3b)
Combined Pre/Post-Transaction Disclosure (CP-3b)
Estimated Post-Transaction Disclosure (ET-3b)

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/03/2011

NOT A RECEIPT
Transfer Amount:
Transfer Fees and Taxes:
Total:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

P-3b

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/03/2011

ABC 123 DEF 456

Date Available:

3/04/2011

Transfer Amount:
Transfer Fees and Taxes:
Total:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

Problems or questions? Contact us
within 180 days at 800-123-4567 or
www.gmt.com. You can contact us for a
written explanation of your rights.
You may have the right to cancel for
a full refund within 24 hours of
payment.
For questions or complaints about
Global Money Transfers, contact:
Maryland Office of the Commissioner
of Financial Regulation
410-230-6077
www.dllr.state.md.us/finance/
Consumer Financial Protection Bureau
800-555-9999
www.cfpb.gov
T-3b

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/03/2011

ABC 123 DEF 456

Date Available:

3/04/2011

Transfer Amount:
Transfer Fees and Taxes:
Total:
Exchange Rate:

$100.00
$10.00
$110.00

US$1.00 = 12.27 MXN

Transfer Amount:
Other Fees and Taxes:
Total to Recipient:

1,227.00 MXN
-40.00 MXN
1,187.00 MXN

CP-3b

Global Money Transfers
1500 Bethesda Avenue
Bethesda, MD 20814
Today’s Date:

3/03/2011

ABC 123 DEF 456
3/12/2011
(May be available
sooner)

Transfer Amount:
Transfer Fees and Taxes:
Total:

$100.00
$10.00
$110.00

Estimated Exchange Rate:
US$1.00 = 12.27 MXN
Estimated Transfer Amount:
1,227.00 MXN
Other Estimated Fees and Taxes:
-40.00 MXN
Estimated Total to Recipient:
1,187.00 MXN

Full text of District Notices (Federal Reserve Bank of Dallas) : Federal Reserve Proposes Rule Under Regulation E to Create New Consumer Protections for Remittance Transfers, Notice 11-31 : Summary of Findings

FRASER