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TCH Seeks CFPB’s Clarification and Guidance on Remittance Issues

The Clearing House Association submitted a letter to the CFPB seeking clarification on various issues related to its remittances transfer rule. In the letter, TCH requests that the Bureau provide clarification and guidance on the following: (i) the definition of a remittance transfer, especially with respect to several specific items, (ii) the definition of remittance transfer provider, including with respect to the distinction between situations involving agents of a provider and those involving multiple remittance transfer providers, (iii) certain aspects of the content and timing requirements for disclosures, and (iv) certain aspects of the error resolution provisions.