The Clearing House Association, along with nine other trade groups, submitted a comment letter to the Fed asserting that the Fed’s proposed Reg E remittance-transfer rules, oriented towards closed networks, are unworkable for open-network (ACH and wire) transfers. The letter urges that the final rule either exclude open-network transfers or provide a separate rule set tailored to such transfers. The letter also suggests that the application of the final rule be limited to transfers in an amount that is consistent with the value of a traditional remittance.