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April 2, 2014 – NAFCU Regulatory Affairs Counsel Angela Meyster wrote the CFPB in response to its proposed rulemaking defining the larger participants of the international money transfer market, and advocated increasing the transfer limit in the existing remittance rule.

"NAFCU appreciates the CFPB's extension of its larger participant rulemaking authority to nonbanks involved international money transfer market because it creates a more level the playing field for other types of participants already subject to the CFPB's remittance transfer rule," Meyster wrote. "However, the existing remittance transfer rule's provisions continue to present significant problems for credit unions. The remittance rule's requirements remain cost prohibitive for many credit unions.

The regulatory burdens imposed by the remittance transfer rule on credit unions have already, and will continue to, lead to a significant reduction in consumers' access to remittance transfer services," she continued. "Many credit unions … have or will be forced to discontinue their remittance programs, and those that continue to offer remittances will be forced to significantly increase their members' fees to access remittance services."

Meyster advocated increasing the 100-transfer limit in order to provide safe harbor for institutions that only offer remittance transfers on a limited basis. She pointed out that an increase would not hurt consumers or limit competition.