Newsroom
NAFCU outlines concerns around Reg E, P2P payments
NAFCU Senior Counsel for Research and Policy Andrew Morris wrote to the CFPB Monday in response to the agency’s request for comment regarding its Paperwork Reduction Act (PRA) notice for Regulation E. In the letter, Morris shares NAFCU’s concerns around the allocation of error resolution responsibilities in the context of peer-to-peer (P2P) payments.
In the letter, Morris draws attention to potential uncertainty around investigations of ‘token errors’ as described in the bureau’s Fall 2021 Supervisory Highlights.
“To mitigate the compliance challenges associated with payment error investigations (and their associated information collection burdens), NAFCU asks that the Bureau clarify expectations around token error investigations, which may be difficult for a credit union to conduct without access to certain information, particularly when the underlying transfer involves a P2P service,” wrote Morris.
In summary, NAFCU recommends that the bureau do the following:
- clarify expectations around token error investigations by specifying that for P2P transfers, P2P providers be primarily responsible for investigation token errors; and
- consider ways to achieve a more equitable balance of error resolution responsibilities that may be shared between financial institutions and P2P payment service providers.
“NAFCU supports clear and fair rules governing error resolution procedures for financial institutions,” concluded Morris. “By clarifying expectations for token error investigations and considering a more equitable framework for allocating Regulation E responsibilities when transfers involve P2P services, the Bureau will improve consumer outcomes by supporting a more efficient error resolution process.”
Read the full letter here. NAFCU will continue to work with the CFPB to ensure credit unions have the tools necessary to operate efficiently and smoothly.
Share This
Related Resources
Add to Calendar 2024-05-03 14:00:00 2024-05-03 14:00:00 Plan Sponsor Attitudes Toward Retirement Plan Management and Fiduciary Outsourcing About the Webinar In January 2024, Pentegra conducted a survey of retirement plan sponsors and their perspectives on retirement plan management and fiduciary outsourcing. The survey measured how sponsors are using fiduciary outsourcing to help better manage their retirement plans. It also captured their perspectives on what outsourcing does to help them better position their plans and drive improved retirement plan outcomes. Key Takeaways: What is the full scope of your responsibilities as a plan sponsor? What is fiduciary outsourcing and how does it work? How does fiduciary outsourcing help reduce workloads and minimize risk? How can a credit union best position its plan to drive improved outcomes? Register Here Web NAFCU digital@nafcu.org America/New_York public
Plan Sponsor Attitudes Toward Retirement Plan Management and Fiduciary Outsourcing
preferred partner
Pentegra
Webinar
Turning Lemons into Lemonade: Capitalizing in a Post-Banking Crisis Era
Strategy
preferred partner
Allied Solutions
Blog Post
Ensuring Safety and Soundness with AI
Management, Consumer Lending, FinTech
preferred partner
Upstart
Blog Post
Add to Calendar 2024-05-02 14:00:00 2024-05-02 14:00:00 Mastering Resilience in Incident Response Plans About the Webinar An Incident Response (IR) plan is crucial for guiding credit unions through major incidents efficiently and effectively. However, many IR plans lack resilience, making them less adaptable to the evolving threat landscape. Join us for our webinar Mastering Resilience in Incident Response Plans where DefenseStorm cyber experts Elizabeth Houser and James Bruhl will delve into the importance of resiliency within cybersecurity IR plans. Don’t miss out on the opportunity to learn how to: Ensure IR plan accessibility so that all team members with assigned roles are prepared for effective incident response. Conduct efficient and regular reviews to ensure roles and responsibilities are current, tools are relevant, and compliance requirements are met. Implement and utilize tabletops to regularly test the effectiveness of your IR plan. Enhance preparedness, efficiency, and confidence among responders. View On-Demand Web NAFCU digital@nafcu.org America/New_York public
Mastering Resilience in Incident Response Plans
preferred partner
DefenseStorm
Webinar
Get daily updates.
Subscribe to NAFCU today.