CFPB Publishes Examination Procedures for Remittance Transfers

The Consumer Financial Protection Bureau (CFPB) published its 67-page Examination Procedures for Remittance Transfers on Tuesday, Oct. 22. While the CFPB only has direct examination oversight for financial institutions with more than $10 Billion in assets, other regulators may look to these procedures when performing their own examinations.

The Dodd-Frank Act expanded the scope of Regulation E to provide protections to members who send remittance transfers that will be received outside the U.S. The rule, which goes into effect on Monday, Oct. 28, applies to credit unions that offer international transfers to their members. It does not apply to credit unions that consistently provide 100 or fewer remittance transfers each year, nor does it apply to transactions under $15.

The CFPB examination guide focuses on:

  • Providing required disclosures: The CFPB remittance rule requires that providers disclose information about certain fees, the exchange rate, and the amount to be received by the recipient. Disclosures must generally be provided when the member first requests a transfer. After payment is made, members are entitled to additional information or, in some cases, a proof of payment.
  • Following proper error-resolution procedures: Remittance providers must investigate and resolve errors. These procedures must include notifying the member of the outcome of the investigation.
  • Offering refund and cancellation rights to consumers: Members may cancel most remittance transfers up to 30 minutes after payment. Examiners will be looking to make sure that the provider refunds the member’s money, at no additional cost to the member, within three business days if the consumer makes an appropriate request in time.

Examiners will also review the activities of international money transfer providers for other consumer risks, including potentially unfair, deceptive, or abusive acts or practices.

The CFPB is coordinating with other regulators to ensure they all have a shared understanding of the CFPB’s new rules. The remittance transfer examination procedures are based on procedures that the CFPB and other examining agencies developed through the Federal Financial Institutions Examination Council.

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance.