The Clearing House Association submitted a comment letter to the FRB proposing a definition of “error” for purposes of the error resolution rules that the FRB must issue under § 1073 (remittance transfers) of Dodd-Frank. TCH suggests that errors exclude unauthorized wires that are effective against the sender under UCC 4A, variances in amount when a financial institution has provided a reasonably accurate estimate of the amount to be received and delays in receipt or variances in amount which are caused by circumstances beyond a financial institution’s reasonable control. The proposed language also preempts UCC 4A-108 so that remittance transfers that are wires remain funds transfers and, as between financial institutions, UCC 4A is still applicable. Finally, the letter requests that the Board limit the application of § 1073 to remittances less than $500.