Alert November 27, 2012

CFPB Plans to Refine Elements of Remittance Transfer Rule

The CFPB issuedbulletin related to the implementation of the remittance transfer rule under Regulation E.  Earlier this year, the CFPB proposed a final remittance rule to become effective in February 2013 (see August 7, 2012 Alert). The bulletin outlines the CFPB’s plan to issue a proposal in December 2012 to "refine three elements" of the rule regarding foreign remittance transfers, including: (1) errors resulting from incorrect account numbers provided by senders of remittance transfers, (2) the disclosure of certain foreign taxes and third-party fees, and (3) the disclosure of sub-national, foreign taxes. The CFPB also plans to delay implementation of the rule at least until Spring 2013, after it finalizes the proposal.

Several Congress members sent the CFPB a letter in August 2012 requesting that it delay the effective date of the rule by two years, citing concerns that the new rule will result in an increased risk on providers and increased costs to consumers (see August 21, 2012 Alert). The CFPB has already released a safe harbor countries list for remittance transfers (see October 2, 2012 Alert), an International Fund Transfers Small Business Compliance Guide (see October16, 2012 Alert) and an unofficial complete Remittance Transfer Rule and Interpretations.