Bank/Thrift Supervision   |    Capital    |    CFPB    |    Deposit Insurance    |    Interchange    |    Mortgage Finance
Municipal Advisors   |    OCC-OTS Merger   |    Preemption    |    QM - QRM    |    Swaps   |    Volcker Rule    |    Full Topics List
Qualified Mortgage - Qualified Residential Mortgage
Consumer Financial Protection Bureau - CFPB
Bank/Thrift Holding Company Supervision
Deposit Insurance
Mortgage Finance
Municipal Advisors
OCC-OTS Merger
Volcker Rule
Corporate Governance
Financial Stability Oversight Council (FSOC)
Office of Financial Research (OFR)
Systemic Risk
Supervision and Oversight
Payment, Clearing and Settlement
Prudential Supervision
Trust & Securities
Asset-Backed Securities
Resolution Authority

Tuesday, April 10, 2012

Proposal to Supplement CFPB Remittance-Transfer Rule Inadequate

The CFPB’s proposed rule that would narrow the “remittance transfer provider” definition, and also refine disclosure requirements for certain advance-schedule transfers does not adequately address the flaws in the CFPB’s remittance-transfer final rule published on Feb. 7, ABA said yesterday in a comment letter.

The proposal is intended to supplement the final rule that requires remittance-transfer providers to disclose to consumers information on fees, the exchange rate and the amount that will be received. In the letter ABA wrote:
[T]he final rule and the attempt to temper it with the current proposal will ultimately reduce the number of consumer funds transfer providers, undermine competition, and cause costs to consumers to increase and quality of service to decline.
The proposal’s safe harbor from the “remittance transfer provider” definition, which would exclude small banks that make fewer than 25 transfers a year, is inadequate because, among other things, such institutions generally make about 25 transfers a month, the letter explained. Adding that without the ability to estimate advance-scheduled transfers, providers would incur far too much risk to offer such transfers under the proposal.

In addition, ABA has joined five other industry trade groups in a comment letter that also opposed the proposal and final rule. The trade groups emphasized that delaying the final rule’s effective date and studying its impact “are critically important.”

Read ABA’s comment letter.
Read the joint comment letter.
Read the proposed rule.

No comments:

Post a Comment

Please read our comment policy before making a comment.