In a joint comment letter with the Clearing House and the Consumer Bankers Association yesterday, the American Bankers Association and its subsidiary BAFT offered support for proposed changes to the Consumer Financial Protection Bureau’s remittance rule. The changes would create two new exceptions—one for exchange rates and one for fees—that will allow banks continue to rely on estimates when providing disclosures to customers. The bureau issued the proposal in response to concerns about a temporary provision of the rule set to expire in July 2020.
The groups also encouraged the CFPB to make greater use of the rule’s country exception, which allows estimation for remittance transfers to certain countries where disclosures can be particularly difficult.
In a separate comment letter, ABA offered support for another proposed change to ensure that small-volume providers—particularly community banks—can continue to offer remittances. The proposal would increase the threshold at which institutions are determined to be sending remittances in the normal course of business (and are therefore subject to the rule) from 100 to 500 remittances per year. The association had urged the bureau to raise the threshold in previous comments.