Remittance Transfer Rule

On May 11, the CFPB issued its Final Rule on Regulation E’s remittance transfers requirements, effective July 21, 2020. In advance of the expiration of a statutory exception in July 2020, the Final Rule amendments allow financial institutions to provide estimates of certain fees and the exchange rates related to remittance transfers if they meet certain conditions. The Final Rule … Read More

CFPB Notice of Proposed Rulemaking to Amend the Remittance Transfer Rule

The CFPB announced its Notice of Proposed Rulemaking (NPRM) regarding remittance transfers requirements under Regulation E.  The CFPB is proposing changes to two areas of the remittance transfer requirements and also asking for comments related to the safe harbor countries list.  The proposed changes include: Increasing the normal course of business safe harbor threshold from 100 to 500 annual remittance … Read More

Remittance Transfers

Unless the CFPB extends or removes the expiration of allowing estimates for remittance transfers, financial institutions will need to make sure their disclosures reflect the actual terms of any remittance transfer. Remind me The requirements for remittance transfer disclosures, under Regulation E, include the ability to estimate certain information included on the pre-payment, receipt, or combined disclosures required for remittance … Read More

More BSA on the way?

In January, the Government Accountability Office released a report, in response to Congress’ request, titled Internal Remittances – Money Laundering Risks and Views on Enhanced Customer Verification and Recordkeeping Requirements. This was initiated from a 2015 Senate bill, the Remittance Status Verification Act of 2015.  While the Act did not proceed further, it would have required remittance transfer providers (including credit unions) to, before … Read More