U.S. topic -- Social Security direct deposit to U.S. bank

[parallaxtech]

JT: It was BB in Chaweng, Koh Samui.  I called BB in Bangkok and Nathon and they all had different answers.  The BB website on direct deposits doesn't mention any of these required items.  It just says to change your regular BB into a direct deposit one by showing your passport.  The gripe I had was that the girl thought it was amusing by having me running back and forth to the Immigration,  accountant, and home.  Update:  SS Manila just emailed a form stating my name, ssn, and benefits, so hopefully this will be accepted by the bank, but I doubt it.  If this fails, I will just have it deposited in one of my US accounts.

[parallaxtech]

JG:  Thanks, your advice makes sense.  I am a little worried about using Fidelity as the last time I spoke to them, they said that they couldn't conduct business with any account holder outside the US and hung up on me.  I have a US UPS address.  I could probably deposit it in BOA.  They will only allow a $5k/day and charge $5 or $30 to send it to BB NY.

[Jingthing]

JG:  Thanks, your advice makes sense.  I am a little worried about using Fidelity as the last time I spoke to them, they said that they couldn't conduct business with any account holder outside the US and hung up on me.  I have a US UPS address.  I could probably deposit it in BOA.  They will only allow a $5k/day and charge $5 or $30 to send it to BB NY.

Yes Fidelity is problematic for expats. There was a report on another thread that to authorize a swift wire agreement for International you need to visit one of their offices and complete a "gold" level signature agreement whatever that is. I somehow doubt they will welcome people to do that without current US state residency ID.

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[JimGant]

This is why Transferwise is slick. They do a direct debit ACH "pull" from your financial account, exactly the same as would a water or electric utility. Fidelity or BofA won't know or care that this money eventually crosses the border -- all's they'll see is a domestic ACH pull into a Transferwise bank account in the US. Yes, the IAT data elements eventually get added to the transaction, but this is done on the TW end. And TW looks like they have been pretty darn careful not to run afoul of any US money laundering laws -- and of US state laws, as they currently can only do some activity in only something like 48 states.

 

So, since you're not doing an international wire "push" or an ACH "push," you're good to go (unless TW gets blacklisted, which seems unlikely).

[Sheryl]

I understand you can apply for benefits online and don't need a myssa account to do that.

 

However if you do open a myssa account with a US address that can be verified with a credit agency will that address be used to send proof of life letters and other correspondence to? I think most expats want those things mailed to their foreign address.

 

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1. Correct. I just did it and it went through (i.e. I got emailed acknowledgement)..

 

2. I don't think so but not 100% sure. I think you can put a different address on your application for benefits. But maybe someone with an online acct can verify.

 

I had initially thought the reason my attempts to create an online acct with a US address got a "cannot verify information" error message was because it was not the same as the address SS has on file (that I get mail from them at -- my Thai address). However turns out not, they do not use the existing SS database for the verification but rather independent commercial sources like Credit Bureaus. One wonders what happens to people without a credit history.

 

Agent did suggest checking back every few months or so as that online system is frequently updated. Maybe in future it will accept foreign addresses.

 

An aside which may be of interest to some: I have learned that having had self purchased insurance if self-employed abroad does qualify one for late enrollment in Medicare Part B under a SEP and without penalty. (Though the language says "group health plan through employment" -- it can be a group of 1 if self employed in a sole proprietorship. You do need to have been both self employed and insured, though.)

 

At least have been so told. It hadn't yet come through.

 

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[Pib]

When creating a mySSA online account if you successfully complete the registration the address you enter during the registration process will "not" appear anywhere.   That address will not appear anywhere after registration unless you are already drawing social security benefits and that happens to also be the address you used on your SSA application.  If already drawing benefits your online account will display additional info in a "Profile" area which shows your address on-file with the SSA, Direct Deposit Info, etc.  If you are not drawing any benefits you shouldn't have a Profile area.

 

The address you enter during the registration process is validated against what is contained in your "Equifax" credit report.  Up until around 2014 your Experian credit report was used.   However, Equifax now has the SSA contract which is used to validate online accounts...the contract runs from 30Sep14 to 30Mar22.     See contract info at this website.  https://govtribe.com/contract/idv/ss001461109

 

To successfully register the U.S. address you are entering must be reflected on your Equifax credit report....and I'm guessing it should be your latest U.S. address but the story I'm about to tell you argues against the "latest U.S. address."

 

In 2013 when the wife was trying to open a mySSA online account, she couldn't get past the first page where you enter some basic stuff like your social security number,  "U.S. address," phone number, etc.   When pressing continue to go to the next page if the address you entered matches what is reflected in the credit report then you are presented the next page which is a Q&A quiz based on your data in the credit report....this quiz of approx 4 questions is part of validation of your identity.    Pass that quiz along with the address match and you have just created your online account.    This is how it worked for both the wife and I in setting opening our online accounts in 2013...it might be a little different now.

 

When you start surfing around your newly created account "and assuming your are not drawing an SS benefits" you will notice no address is reflected.   As mentioned the address you entered during the online account registration was not changing/establishing your address with SSA; it was just needed as part of the account setup/validation process....needed/used to buck against the address data in your credit report.

 

Anyway, initially she could never get past the first page of the registration process because an error would appear talking "can not validate address."  You can try to enter a variation of the same address or another address (like an earlier address) three times before it will lock you out.   If locked out you may be locked out for only 24 hours or you may be locked out until you call SSA, explain the issue, and they unlock it so you can try again.  The lock-out/block is based on your social security number.

 

Now the wife and I have been married for decades....had the exact same addresses during all those decades....filed joint returns for decades....got bank accounts, investments, loans, credit cards, etc., all using the same address.   The addresses on our individual credit reports are same-same.   When I created my SSA online account earlier in 2013 I used our current address....a U.S. APO mailing address here in Thailand....the wife and I had been using that APO address for everything for 5 years already....federal joint returns, bank accounts, investment accounts, credit cards, life insurance policies, just everything.   But when she tried to register a SSA online account using that APO address...her address for 5 years already and which worked fine for my registration a few days earlier....it simply would not validate that address for the wife. 

 

So, we call SSA and explain the problem.  After the SSA rep asks the wife some questions to validate her identity, the rep removes the block preventing account registration so she can try to register again.  She tried again with abbreviation variations of our current address as recommended by the SSA rep....didn't work...after three failed attempts...got locked again...but the rep immediately unlocked for more tries. 

 

By the way, the SSA rep said don't worry about the phone number entry as that's not bucked against anything.  In fact you can leave it blank the rep said.  But that was back in 2013 when your  phone number was used for info only.   However, now it would be used to send you a secure code via text message if you didn't choose to use an email address instead....so, today the a U.S. phone number (Google Voice works for this) might have to be entered to complete the registration.

 

Anyway, back to the story.  The rep then told the wife to try an "older, previously lived at" address.  She entered our U.S. address from 5 years earlier---Success!!!...got past the first page...passed the Q&A quiz and the account was opened.   Surf around the account...the  address used to register is not listed anywhere...in fact no address of any kind anywhere on the account. Like mentioned earlier it's just used for the identify validation against your credit report.   But once you start drawing a SS benefit a new Profile area will appear with the address you have on-file with SSA as mentioned earlier.

 

So, if you try to open an online account, have been living in Thailand for a long time, but still using a U.S. address for anything that might get reported to a credit report agency then you should be able to create an online account using that address.  And if that U.S. address don't work, try the U.S. address you have before that.  Just remember you only get 3 attempts at entering an address that is accepted (i.e., can be matched up with your credit report) before you will get locked out which will require you to call the SSA to get the lock removed....or that is how it was in 2013...probably the same today.

 

Edited August 11, 2018 by Pib

[Pib]

And just to confirm the SSA uses Equifax, see below SSA wepage.

 

https://www.ssa.gov/hlp/mySSA/df-idverification.html

[Jingthing]

Thanks again for all that.
Now I'm wondering push come to shove is it really worth any risk to create a Myssa account if you're really living abroad and need to deal with the foreign services office in Manila anyway?

What's the big benefit that would be worth any risk?

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[Jingthing]

Here's another fun question.

So we know for sure SS does get address info from our IRS tax forms.

Because of the online tax service I use the address I gave to IRS is quite weird and quite different from what I would write here.

I'm planning on giving SS when applying for benefits (as opposed to myssa which doesn't accept foreign addresses in any format) a properly written and rather long Thai address.

One reason is I think it would be more reliable to get mail even though the IRS address has worked.

So that proper address will be in the SS system via Manila.

But I will need to keep using the truncated and weird Thai address to IRS.

The street numbers are the same though.


Do you think the IRS filings will be used to update the address I give to Manila? Of course I wouldn't want it to and maybe it would be OK if it did but I'm curious.

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[Jingthing]

I looked into their debit card system where you don't need to use any bank.

Horrible!

Three percent foreign exchange charge plus any ATM charges.

I suppose you could find a bank that would do large teller withdraws though.

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[Pib]

7 minutes ago, Jingthing said:

Three percent foreign exchange charge plus any ATM charges.

 

3% "plus $3" plus any ATM charges for a foreign transaction.  Fine card to use in the U.S. but expensive to use outside U.S.

[Jingthing]

I'm not a member of ACA (American Citizens Abroad) the expats lobbying group but that seems like something they should be lobbying S.S. to change especially considering the issues Americans have with even opening accounts in some countries because of the extra reporting required and also the fact that many expats don't have US accounts either.

 

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[Thailand J]

It is true Fidelity insists on a medallion signature to set up a standing wire transfer.  The medallion signature guarantee is not available outside of US.

Vanguard accepts US embassy  certification as a substitute.

Schwab only needs the signature of the account holder.

To get money from my Fidelity account I have to go to Vanguard or Schwab to pull the money and wire it to Thailand.

It is possible to call Fidelity to order a wire tranfer for a low $15 fee without any paperwork. It is very easy to verify your identity once you've been enrolled to their computer voice recognition system.  Their computer memorizes 50 to 100 words from your voice as you speak to an agent and use those for future verification. Very cool.

 

 

[Moon37]

I have my SS check deposited in my US Bank and then use the following system to get it in my Bangkok Bank account.

This is a very easy solution for transferring funds from your US bank to Bangkok Bank.  

Bangkok Bank’s New York branch is a US federally chartered branch functioning as a wholesale bank.

I have a monthly amount sent to an account I set up between my US Bank account and a Bangkok New York.account

The money does not stay there and is automatically forwarded to my Bangkok Bank account here (for only $3.50 per transaction)

Their website explains it all.

http://www.bangkokbank.com/BangkokBank/InternationalNetwork/InternationalBranches/USA/Pages/Content2.aspx Edit: New link https://www.bangkokbank.com/en/Personal/Other-Services/Transfers/Transferring-Into-Thailand/Transfer-money-from-US-to-Thailand-via-Bangkok-Bank-NewYork-branch (they revamped their website on 25 Aug)

 

The Bangkok Bank New York

29 Broadway, 19th Floor

New York , NY, 10006

1-212-422-8200  (This lady is very helpful)

email.   [email protected]

Edited August 26, 2018 by ubonjoe

[Jingthing]

19 minutes ago, Moon37 said:

I have my SS check deposited in my US Bank and then use the following system to get it in my Bangkok Bank account.

This is a very easy solution for transferring funds from your US bank to Bangkok Bank.  

Bangkok Bank’s New York branch is a US federally chartered branch functioning as a wholesale bank.

I have a monthly amount sent to an account I set up between my US Bank account and a Bangkok New York.account

The money does not stay there and is automatically forwarded to my Bangkok Bank account here (for only $3.50 per transaction)

Their website explains it all.

http://www.bangkokbank.com/BangkokBank/InternationalNetwork/InternationalBranches/USA/Pages/Content2.aspx

 

The Bangkok Bank New York

29 Broadway, 19th Floor

New York , NY, 10006

1-212-422-8200  (This lady is very helpful)

email.   [email protected]

Yes, but that ACH method is set to end in April 2019. That has been discussed extensively on the forum. At the current time, people aren't even able to set up new ACH links for this method. You'll need to find another transfer method. 

[Pib]

Unfortunately there are people who will only become aware of the Bangkok Bank policy change when their ACH automatic or manual transfer from their a U.S. bank to Bangkok Bank gets rejected starting 1Apr 19.

[joealx]

On 8/20/2018 at 1:09 AM, Jingthing said:

Yes, but that ACH method is set to end in April 2019. That has been discussed extensively on the forum. At the current time, people aren't even able to set up new ACH links for this method. You'll need to find another transfer method. 

Doesn't this apply to regional banks and credit unions that are not members of the Federal Reserve? A lot of  scare·mon·ger·ing going on here.

[Pib]

7 minutes ago, joealx said:

Doesn't this apply to regional banks and credit unions that are not members of the Federal Reserve? A lot of  scare·mon·ger·ing going on here.

It applies to any financial institution (bank, credit union, brokerage, etc) which uses the ACH system which is the primary funds transfer system used in the U.S. 

 

 No scaremongering here...just financial institutions complying with U.S. Treasury and NACHA rules.

[joealx]

12 minutes ago, Pib said:

It applies to any financial institution (bank, credit union, brokerage, etc) which uses the ACH system which is the primary funds transfer system used in the U.S. 

 

 No scaremongering here...just financial institutions complying with U.S. Treasury and NACHA rules.

 

12 minutes ago, Pib said:

It applies to any financial institution (bank, credit union, brokerage, etc) which uses the ACH system which is the primary funds transfer system used in the U.S. 

 

 No scaremongering here...just financial institutions complying with U.S. Treasury and NACHA rules.

Please read the notice from Bangkok Bank again.

Important Note: 

• As some bank in U.S. may not provide the International ACH thorough their internet banking, please contact your bank on how to process your transfer.
• Once Bangkok Bank’s New York branch receives the payment with the appropriate IAT format, they will process your payment to Bangkok Bank in Thailand for further credit to a recipient's bank account at Bangkok Bank in Thailand.
• With effective from April 1, 2019, New York branch only process ACH with appropriate IAT format and all non-IAT transactions will be returned.      
• Bangkok Bank in Thailand will be able to credit the recipient’s account in Thailand only when the name and account number of the recipient in your transfer instruction from the banks in the U.S. matches the recipient’s name and account number at Bangkok Bank.

[Pib]

1 minute ago, joealx said:

 

Please read the notice from Bangkok Bank again.

Important Note: 

• As some bank in U.S. may not provide the International ACH thorough their internet banking, please contact your bank on how to process your transfer.
• Once Bangkok Bank’s New York branch receives the payment with the appropriate IAT format, they will process your payment to Bangkok Bank in Thailand for further credit to a recipient's bank account at Bangkok Bank in Thailand.
• With effective from April 1, 2019, New York branch only process ACH with appropriate IAT format and all non-IAT transactions will be returned.      
• Bangkok Bank in Thailand will be able to credit the recipient’s account in Thailand only when the name and account number of the recipient in your transfer instruction from the banks in the U.S. matches the recipient’s name and account number at Bangkok Bank.

Yes.  Unfortunately financial institution do not provide International ACH Tranactions (IAT) for retail accounts; only the current Domestic ACH Transactions.  International and Domestic ACH transfers used different formats....the International format requires additional information.    IAT is only provided for some business accounts for payment of international goods/services, payroll, etc.  And of course bank provide International Wire (a.k.a., SWIFT) transfers for retail accounts and the info provided in International Wires mirror info required in IAT.

 

Might be best if you go read through below thread which has more detail on the change going in effect 1 Apr 19 for transfers from financial institutions.  However, U.S. govt payments such as social security, military retirement, etc., are not affected as those payments are coming from Uncle Sam and not a financial institution such as your bank, credit union, etc.  

 

 

[Jingthing]

Yes. Not scare mongering at all. Reality.

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[Pib]

Some people are just not going to get the word or believe it until their bank transfers from their U.S. bank to their Bangkok Bank account get rejected starting 1 Apr 19.   

 

And as some have already found out and posted in other similar threads starting around Mar 18 (eighteen) they could no longer setup a "new" ibanking ACH transfer link to Bangkok Bank which used the "trial/micro deposits" validation method as Bangkok Bank New York branch started rejecting such new transfers unless in the IAT format.   The person's U.S. bank just gets a rejection notice from the NY branch, no trial deposit arrive/can get past the NY branch, and the person can not validate the final setup of the new transfer link that relies on trial deposits.   Then if wanting to send money from directly their U.S. bank  to Bangkok Bank they must use an Int'l Wire (SWIFT) which is usually pricey and/or not as easy to initiate as an ACH transfer.   Then there is always the method of using a money transfer service like Transferwise which pulls money from your U.S. bank account and then they do an international type transfer that includes all the info required in an Int'l Wire or IAT.

 

However, a person's "already established" transfer link will still work until Apr 19 and a new transfer link can be still setup if the person's U.S. bank does "not" use the trial deposit method, but most/many only use the trial deposit method...only a minority offer a non-trial deposit setup method.   

 

But come 1 Apr 19 all ACH transfers from banks/credit unions/financial companies/etc.,  (even from established transfer links) will be rejected by Bangkok Bank unless transmitted in the International ACH Transaction (IAT) format which is not used for retail accounts.  Bangkok Bank knows this but they have no choice due to the U.S. Treasury/NACHA rules.

 

Yeap, some folks are just not to get the word or believe it until their ACH transfers to Bangkok Bank stop working come Apr 19.

 

[ThaiBunny]

Thanks again for all that.
Now I'm wondering push come to shove is it really worth any risk to create a Myssa account if you're really living abroad and need to deal with the foreign services office in Manila anyway?

What's the big benefit that would be worth any risk?

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I have one (with a non-US address I must add) and I find it of marginal utility at best. Having dealt with government Apps in several countries I find it among the worst - almost no self-service functions at all. The annual letter to prove I’m still alive is received and replied via “snail mail”. It requires 2FA to logon which means if you are not in the US getting the code via email rather than SMS. Its one advantage is the ability to print out a letter confirming entitlement if ever required. It also has the date of next payment which may be useful if the next regular payment falls on a weekend or US public holiday. But I wouldn’t lose any sleep about not having it

[Pib]

On 8/10/2018 at 1:40 PM, JimGant said:

Plus, you can set up a recurring transfer with TW, or not -- if you don't want an automatic dump same time every month. AND big plus -- you don't have to send to BB with TW. If the most convenient bank to you is SCB, that's where you open an account, and that's where you have TW send the money. And , since such an account wouldn't be a restricted DD account, feel free to  tap it with ATM, and online, or by anyone you choose -- should you break your back.

Jim,

  To the best of my knowledge...looking around my TW account...and googling the subject....at this time you can not setup an "automatically" reoccurring transfer.     I know you didn't say "automatically"  and  maybe you didn't mean that and it's just me assuming that's what you meant. 

 

  Like once you set up a transfer you can also set it to automatically do the transfer on the 10th of every month for X-amount like you can do with many U.S. ibanking transfer setups....set it up and you don't even have to logon again and the transfer will continue to go out every month/week/etc., until you log back on and cancel this automatic transfer. 

 

   With TW you can indeed log onto your account, select "repeat"  a previous transfer which saves you some reentering some info...but you still have to enter some info again like purpose of transfer...and then walk through the remaining steps of funding the transfer.  And each time you want to repeat this transfer you have to logon, select repeat a certain transfer....do this...do that...etc.  Definitely not automatic and maybe you didn't mean that.

 

[JimGant]

Good catch, Pib. I got caught up on this sentence (I guess in Estonia 'automatically' involves finger intervention):

Quote

If you've made a transfer before and want to repeat it, you can do this automatically from three different places:

 

[Pib]

If would definitely be a nice feature.   Where I mentioned I had googled the subject on the Transferwise twitter page people have been asking for the capability for years...back as far as 2015.  Like below partial snapshot of a running thread on the subject.   I'm thinking Transferwise is not really committed to adding such a feature...probably not due to programming as I figure that would be easy to add the feature to transfer software.  Probably more to do with other problems/issues it would cause like maybe too many transfer fundings bouncing/rejecting due to inadequate bank account funding when the debit  transaction hit a person's bank account and Transferwise just don't want those headaches right now.   Or maybe also they know such headaches would generate more social media complaints....or maybe regulatory issues/complaints.   Yea, I figure it must be some other issues/problems other than software programming as to why Transferwise hasn't implemented this capability yet.

 

[JimGant]

Here's an interesting twist.....

Yesterday, after doing an ACH transfer to my Bangkok Bank account, using my USAA online account, I decided to try the domestic "wire transfer" option from the same dropdown box as the ACH transfer option. However, unlike with the ACH option, where the receiving account has to be pre-approved (e.g.,the trial deposit drill), for a wire transfer you fill in the details on the fly.....

Quote

• Amount you want to send
• Full name of the recipient (person or business)
• Recipient's ZIP code
• Recipient's transit routing number [ABA] for the recipient's bank
• Recipient's bank account number

Thus, I used my wife's name as recipient (it's a joint account, but that turned out not to be a problem), and Bangkok Bank NY's ABA number, and our account number in Thailand (samo samo as for an ACH thru BB NY to Thailand). For ZIP code, I used Bangkok Bank NY's code -- as the fill-in-the-blanks statement just said "ZIP code," and nothing about it being the recipient's (turns out you could use any US ZIP code, as it doesn't attach to anything else -- it's just a confirmation of sorts that this is, indeed, a domestic wire transfer).

 

Now, before I could begin filling in the online wire transfer request, USAA sent a one time password SMS, and fortunately I have Google Voice as my mobile number, so it ends up in my email box. Then the good news -- the fee box said something like, "fee waived, thanx for being a loyal USAA customer." I don't know the criteria for this -- maybe being a USAA member for 51 years counts for something..... Anyway, no $20 fee, thus same cost (free) as an ACH transfer.

 

I had initiated the ACH transfer at 11:00AM Thai time (4 Sep), and the wire transfer at 11:10AM Thai time. USAA acknowledged the wire transfer request right away, and 7 hours later confirmed that the wire transfer was completed.

 

Today, 5 Sep, I received the wire transfer into our Bangkok Bank account at 9:48AM Thai time. At 10:05AM, I received the ACH transfer. Thus, no speed advantage for a wire transfer, at least in this example.

 

As you would expect, Bangkok Bank's fees for a wire transfer match those for an ACH transfer. I this case, I had sent a token $1000 to check things out, and the front end fee was $5, back end fee, 200baht.

 

So, it would appear that, since ACH and wire transfers are both electronic fund transfers (EFT), Bangkok Bank treats them the same. However, what happens come April 2019?  The Feds have told Bangkok Bank that domestic ACH transfers, if repackaged into international ones, have to have additional data elements. But, what about domestic wire transfers?  Hmmmm. Suspect Bangkok Bank will require domestic wire transfers that are repackaged into international transfers to contain the data elements now required for international wire transfers -- or just be international wire transfers, period. We'll see. If not, well, a nice alternative to  TransferWise, who charges $93 for a $10,000 transfer, whereas USAA only charges $20 for a $10,000 transfer (or nothing, if the fee is waived).

 

Your US bank wire transfer scenario vis-a-vis Bangkok Bank obviously won't be identical to USAA. But if the fee is reasonable -- and you're having trouble establishing an ACH connection due to the trial deposit requirement -- a domestic wire may do the trick (until maybe April 2019, anyway).

 

 

[Pib]

Jim

   Specifically what wire transfer menu are you talking.  When I click My Tools, Transfer, Wire Transfer I end up getting a response of:

 

And I've got the same response before several times when clicking the wire transfer function....not just today only.  From looking at their Q&A on the subject I think you first have to call them to activate that function and/or initiate one wire transfer via phone call which also activates the online function.

 

Maybe you did a wire transfer sometime in the past via telecon and that's why its available to your online?

 

Additionally, the last couple of ACH transfers I did to Bangkok Bank from USAA arrived with 24 to 36 hours...USAA don't mess around in getting a person transfer kicked out the door.

 

Also, did notice of the $20 fee waiver appear "before" you clicked whatever button to "finalize the transfer/it's now a done deal".... or did the fee waiver notice appear "after" you clicked the final/done-deal  button?   Your post sounds like the fee waiver notice was before you had to click the done-deal button but I just want to be sure. 

 

 

 

Edited September 5, 2018 by Pib

[JimGant]

Pib, yeah I did some international wire transfers a few years ago, but never a domestic variety. These were all by phone, as you can't do international wire transfers online. However, you can have templates on file with all the transfer data on hand, except for amount to send.

 

The fee waiver is advertised before you even fill in any details.

 

You can also send a domestic wire from a USAA investment account. Curiously, when you do this, they ask for a few more details, like physical address of sender. I wonder if a Thai physical address would trigger a "tilt" at USAA......

 

Quote

    The amount you want to send
    Full name of the recipient (person or business)
    Recipient's transit routing number
    Recipient's physical address
    Recipient's account number
    Name of the bank receiving wire
    Address of bank receiving wire.

 

 

[Pib]

OK, that probably explains it...you had already done some wire transfers.  Expect when you did those earlier Int'l transfers it activate the ability to do online domestic transfers.