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TCH Comments on Proposed Remittance Transfer Reporting

The Clearing House Association joined by four other trade associations submitted a comment letter to the FRB, FDIC and OCC on their proposal to revise the Call Report and add a new Item 16 to Schedule RC-M. Item 16 would assist the Agencies with their supervisory responsibilities related to the new consumer protection regime created by Section 1073 of Dodd Frank Act and provide metrics by which the Agencies and the CFPB can gauge the impact of the Rule on the remittance transfer market. In the letter TCH requests that: (i) the remittance transfer reporting be conducted through an annual or semi-annual survey of all remittance transfer providers rather than through the Call Report, (ii) the comment period to respond to the proposed volume, value, and Temporary Exemption reporting in Item 16(e), be extended until at least two quarters after the effective date of the final Rule, (iii) institutions be required to report only remittance transfers for which they are the remittance transfer provider, and certain other changes.