Removing Barriers Blog

Comments submitted to the CFPB in response to remittance rule RFI
Posted June 27, 2019 by CUNA Advocacy

CUNA submitted its comment letter on the CFPB’s remittance request for information, which the CFPB issued in April following months of meetings in which CUNA raised the issue with CFPB leaders and staff.  The letter states that substantive amendments to the remittance rule would create a more effective balance between consumer protection and access to services. 

“We appreciate the Bureau engaging in its current effort to consider potential revisions to the remittance rule and support the current leadership in its goal to issue right-sized regulations after soliciting meaningful stakeholder feedback,” the letter reads. “While CUNA supports appropriate safeguards for consumers initiating remittance transfers, including clear and understandable disclosures, the Bureau should propose and finalize substantive amendments to the Remittance Rule to better balance necessary consumer protections with a more tailored regulation that allows consumers to access desired products and services.”

The CFPB finalized the rule in 2012 and added a safe harbor later that year for entities that conduct 100 or fewer remittance transfers in the current and prior calendar years. The safe harbor was intended to give small entities such as credit unions relief from burdensome requirements while allowing them to offer remittances as a member convenience.

CUNA believes the safe harbor has not been robust enough to prevent numerous credit unions from withdrawing or limiting remittance services. CUNA’s letter cites the CFPB’s own October 2018 report on the rule which show that costs and challenges association with the rule has likely negatively impacted the availability of remittances at small financial institutions.

CUNA called for three specific key revisions to the rule:

  • Increase the “normal course of business” threshold to at least 1,000 remittance transfers in each of the prior and the current calendar years, up from the current 100;
  • Eliminate the 30-minute cancellation requirement or provide consumers the ability to opt-out of the mandated waiting period; 
  • Urge Congress to make permanent the temporary fee estimates exemption and explore alternative options to allow fee estimates for remittances sent over open-networks.