The CFPB issued examination procedures to incorporate the remittance transfer rule finalized and amended several times (see May 14, 2013 Alert). The focus of the examination procedures reportedly will be in 3 areas: (1) providing required disclosures concerning fees, exchange rate, and the amount the recipient will actually receive; (2) error resolution procedures (including notifying the consumer of the outcome); and (3) refund and cancellation rights—including refunding the full transfer amount within three days if the consumer cancels the transfer within thirty minutes of payment. To assess compliance with the remittance transfer rule, examiners will focus on compliance risk management systems, identifying specific practices that drive risk, and fact-gathering to identify potential violations of consumer law, among other areas of focus. The rule became effective October 28, 2013.
Alert October 29, 2013