Removing Barriers Blog

Comments sent to CFPB for proposed remittance rule
Posted January 22, 2020 by CUNA Advocacy

CUNA wrote the CFPB in response to their proposed rule making several changes to the remittance rule, including raising the “normal course of business threshold” to 500 remittance transfers per year.  In the letter, CUNA wrote that the CFPB should explore several revisions and additions to its remittance rule. 

The CFPB’s remittance rule establishes consumer protections for covered international money transfers. CUNA’s outreach to Leagues and credit unions regarding the rule’s impact has shown that the compliance resources needed to offer the service has led many credit unions to discontinue offering it.

CUNA recommends the CFPB:

  • Increase the “normal course of business” safe harbor threshold to 1,000 remittance transfers, up from the proposed 500 as proposed; 
  • Increase the thresholds for both the proposed exchange rate exemption and third-party fees exemption to 2,000 or fewer transfers to reflect a “normal course of business” safe harbor threshold set at 1,000 transfers, as recommended; and 
  • Eliminate the 30-minute cancellation requirement or provide consumers the ability to opt-out of the mandated waiting period. 

CUNA’s analysis shows, under the current 100-transfer threshold, 96% of all credit union remittance transfers are covered by the rule and must comply with its requirements. Raising the threshold to 1,000 would provide relief to 300 credit unions, while still covered 84% of all remittances made by credit unions.