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CUNA Seeks Feedback on CFPB's Proposed International Remittance Transfers Rule

The Credit Union National Association (CUNA) is seeking credit union feedback to their Regulatory Call to Action through May 12 on the Consumer Financial Protection Bureau's (CFPB’s) recent proposed rule to modify its international remittance transfers rule. CUNA continues to advocate to the CFPB to improve the remittance rule, including to provide a much higher exemption level for credit unions. They are interested in how these proposed changes would affect the processing of international funds transfers at credit unions and their payment providers. The CFPB will accept comments for 30 days following publication in the Federal Register, which is expected shortly.

The proposed rule would extend for an additional five years a temporary provision that permits federally-insured credit unions and other depository institutions to estimate certain pricing disclosures. This temporary provision is set to expire on July 21, 2015. Also, the proposal would make several clarifications and technical corrections, including to:

  • Consider whether U.S. military installations abroad should be considered to be 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, separately, clarify that 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; 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 BSA, OFAC, or similar requirements; and, separately, clarify remedies for certain errors.


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