NAFCU to CFPB: Expand remittance 'safe harbor'
June 9, 2014 – NAFCU Regulatory Affairs Counsel Alicia Nealon asked CFPB to expand the “safe harbor” remittance rule threshold in a letter Friday on proposed remittance rule changes.
Nealon asked that the agency expand the 100-remittance transfer threshold for the safe harbor from the “remittance transfer provider” definition so more credit unions may continue to offer remittance transfer services.
“NAFCU has heard from a number of its members that, because of the final rule’s compliance burden, they have been forced to discontinue, or will be forced to discontinue, their remittance programs,” Nealon wrote. “A 2013 NAFCU survey of our members found that over one-quarter of those that offered remittance services before the final rule have now stopped offering that service to members and even more are considering dropping.
“Those that continue to offer remittances have been forced to significantly increase their members’ fees,” she continued. “This demonstrates that the 100-remittance transfers allowance threshold is too low.”
Nealon went on to respond to the agency’s proposed changes, including the proposed extension of a temporary exception for disclosures, clarifications regarding non-consumer accounts, faxes and oral disclosures, and the rule’s application to military installations.