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CFPB should revisit 100 transfers-per-year exemption: CUNA
WASHINGTON (1/30/13)--Noting that "no issue regarding international remittance transfers is more important to credit unions than the exemption level," Credit Union National Association Deputy General Counsel Mary Dunn urged the Consumer Financial Protection Bureau to reconsider the 100 transfer exemption level in a comment letter sent to the agency this week.

Under the final remittance rule published last February, remittance transfer providers will be required to provide prepayment and receipt disclosures to the consumer sender that include the exchange rate, certain fees and taxes associated with a transfer, and the amount of money that will be received on the other end of the transfer. Remittance transfer providers will also be required to investigate disputes and correct errors.

The CFPB has provided a safe harbor exemption from the rule for remittance providers that transact 100 or fewer remittances per year. 

Dunn in the comment letter said the CFPB's final remittance rule "should differentiate between entities that are profiting as a result of offering remittance transfers as a business line or a product, as opposed to credit unions that offer international remittance transfers as a service to their members who prefer to conduct their financial business with their credit union." She noted that a number of credit unions lose money, or only charge enough money to cover the costs of providing remittance transfers.

The CUNA comment letter also encouraged the agency to use its exemption authority to shield as many credit unions as possible from the terms of the remittance regulations, and to delay the compliance date for the regulations by at least 12 months. "This approach will help facilitate compliance for credit unions, particularly those that work with corporate credit unions, vendors and other third-parties, while minimizing regulatory burdens on all credit unions," Dunn wrote. The letter also commended the CFPB's decision to delay the effective date of pending remittance transfer regulations.

The agency could also ease the regulatory burden faced by credit unions and other financial institutions by compiling and maintaining its own central database of foreign taxes and recipient institution fees. The agency has proposed requiring each remittance provider to find and maintain this information independently. This approach would prove "incredibly burdensome and costly" for credit unions and other institutions. A single, CFPB-maintained database would benefit credit unions and consumers alike, CUNA said.

The CUNA comment letter also addressed:

  • Liability issues;
  • Fees; and
  • Foreign tax issues.
For the full comment letter, use the resource link.
Other Resources

CUNA Comment Letter
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