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.