The Clearing House Association’s comment letter to the CFPB responded to the Bureau proposal to (i) exclude providers that send 25 remittance transfers a year from the Regulation E remittance transfer requirements and (ii) refine the disclosure and cancellation requirements for preauthorized transfers. TCH (i) asserted that 25 transfers a year is too low to be a useful exemption and (ii) argued that providers should not have to guarantee an exchange rate for a transfer scheduled more than one day in advance. In addition, TCH reminded the CFPB that the overall impact of the remittance transfer regulations may make the issue of preauthorized transfers moot because many financial institutions will no longer offer international transfers to consumers at all. TCH urged the CFPB to assess the impact of the final remittance transfer rules on the market for consumer international transfer services and delay the effective date of the final rule.