The Clearing House Association filed a comment letter with the CFPB proposing modifications to the final remittance transfer rule. TCH asked the CFPB to consider (i) a phased-in implementation of the final rule, (ii) a change to the strict liability regime for incorrect sender information, (iii) the elimination of the foreign tax disclosure, (iv) a process by which the industry may recommend countries be added to the safe harbor list, and (v) that the agency express its support for a proposed changed to Section 4A-108 of New York's commercial code.