January 25, 2013

Remittance disclosure complexities examined

1-24-13 Mary-Lou Heighes, NAFCU webcast
Mary-Lough Heighes provided an
overview of the CFPB's remittance
rule provisions.

Jan. 25, 2013 – NAFCU webcast participants on Thursday learned about the proper policies and procedures that are needed to comply with the CFPB's international remittance disclosure rules, including the necessary calculations for rate, fee and tax information and the timing of disclosures.

The CFPB has proposed a delay of the original Feb. 7 effective date for the final rule on remittance transfers. The new effective date will be determined when the proposed rule is finalized. While NAFCU supports the delay, the association believes it will not solve the numerous problems credit unions will encounter once the rule is implemented.

Thursday's webcast, which was led by credit union compliance expert Mary-Lou Heighes, president and founder of Compliance Plus, Inc., provided an overview of the disclosure rules and their inherent challenges. In addition to information on rate and fee calculations and the timing of disclosures, Heighes covered the rules relating to error resolution, as well as proposed changes from the CFPB and specific compliance deadlines.

On the issue of prepayment disclosures, Heighes noted that credit unions have the option of providing the sender a combined disclosure at the time of request in lieu of the prepayment disclosure and sender receipt as long as they provide proof of payment at the time the payment is made. However, she said the proof of payment must be clear and conspicuous, in writing or in electronic format and retainable.

Thursday's webcast is archived and will remain available for one year. The price for the on-demand webcast is the early-bird rate. NAFCU extended this rate due to the importance of this new regulation.