In response to a recent request for information, the American Bankers Association on Friday filed two comment letters offering feedback to the CFPB on potential changes to its remittance rule. The bureau issued the RFI ahead of the July 2020 expiration of a temporary provision allowing depository institutions to estimate certain fees and exchange rates when making disclosures to their customers. The CFPB is seeking to ensure that consumers can continue to have access to remittances beyond that date.
In a joint letter with three other industry groups, including BAFT—ABA’s global transaction banking subsidiary—ABA recommended that the CFPB use its authority permit banks to provide estimated disclosures so that they can continue offering remittance services to customers. The groups pointed out that the current use of estimates has never been the subject of consumer complaints.
ABA filed a second comment letter encouraging the CFPB to ensure that small-volume providers—particularly community banks—can continue to offer remittances. ABA urged the CFPB to raise the threshold for exemption from the rule from 100 remittances per year to 500 remittances per year.