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The Consumer Financial Protection Bureau's final rule on electronic remittances allows consumers 30 minutes instead of the proposed business day to cancel a remittance request – one of the key changes NAFCU advocated when the rule was proposed.

Revisions to Regulation E that made way for the CFPB's final rule on electronic remittances were originally proposed by the Federal Reserve in July 2011. The bureau finalized the rule in line with Dodd-Frank Act changes that charged the CFPB to issue rules on remittance transfers.

The rule simplifies, to some extent, the disclosure process for recurring remittance transfers established in order to pay recurring bills – another key item NAFCU pushed for on behalf of its member credit unions, according to NAFCU Regulatory Affairs Counsel Dillon Shea. Though the final rule's treatment of recurring remittance transfers is an improvement over the Fed's proposal, NAFCU continues to believe that the disclosure process for recurring transfers is unduly burdensome, Shea said.

Like the Fed proposal, the CFPB's final rule also requires providers of remittance transfer services to provide a written prepayment disclosure explaining the exchange rate, applicable fees and taxes and the amount the recipient will receive.

The rule allows for two exceptions that permit remittance transfer providers to give estimates for the prepayment disclosure requirement. The first is a temporary exception for insured depository institutions that will expire in July 2015. The CFPB can extend the temporary exception, but the bureau won't decide that until the deadline draws closer. The second exception also allows for estimates for the required disclosure items if the laws of the recipient country make it impossible to determine in advance the exact amount the recipient will receive.

In addition to the final rule on electronic remittances, the CFPB issued a proposed rule and request for comment that seeks feedback on the disclosure process for recurring remittance transfers. NAFCU was part of larger group of interested parties who met with CFPB in November on the issue of remittances. The association will continue to advocate for a simplified, streamlined disclosure process for these transactions.

The proposed rule also seeks comment on whether it should allow an exception for institutions that infrequently provide remittance transfer services. In its discussions with the CFPB, NAFCU advocated on behalf of its members for such an exemption. "We think an exception could be potentially very helpful for small institutions," said Dillon.

The final rule will go into effect one year after it is published in the Federal Register.