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Washington
Remittance rule comment deadline extended by 10 days
WASHINGTON (5/14/14)--The Consumer Financial Protection Bureau has extended the comment period for the modifications to its international remittance transfers rule. The comment period will now close June 6.

The new rule would extend a temporary provision, which is set to expire July 21, 2015, by an additional five years. The provision permits federally insured credit unions and other depository institutions to estimate certain remittance pricing disclosures.
 
The Credit Union National Association encourages credit unions to comment as the trade association works for improvements to the proposal, including an exemption level well over the 100 transfers per year that the CFPB currently provides.
 
Also, the proposal would make several clarifications and technical corrections, including to:
  • Consider whether U.S. military installations abroad should be considered being located in a U.S. state or a foreign country for purposes of the remittance rule;
  • Clarify that transfers from accounts primarily used for personal, family or household purposes would be subject to the remittance rule, but transfers from non-consumer accounts would not be subject to the rule;
  • Clarify that faxes are considered writings and would not be subject to additional requirements for electronic disclosures; and, separately, in certain circumstances, a remittance transfer provider may conduct the transaction orally and entirely by telephone after receiving a remittance inquiry from a consumer in writing (e.g., if a sender physically abroad a U.S. branch of a sender's institution attempts to initiate a transfer by first sending a mailed letter, and further communication by letter may be impractical.); and
  • Clarify that a provider's failure to deliver a transfer by the disclosed date of availability is not an error if such failure was caused by a delay related to a necessary investigation or other action to address Bank Secrecy Act, Office of Foreign Assets Control, or similar requirements; and, separately, to clarify remedies for certain errors.
CUNA continues to advocate to the CFPB to improve the international remittance transfer rule for credit unions, and is interested in how these proposed changes would affect the processing of international funds transfers at credit unions, corporate credit unions and other payment providers.
 
Use the resource link to access CUNA's Comment Call. CUNA's comment deadline has been extended to May 30.
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