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TCH’s 2019 Comment Regarding Potential Regulatory Changes to the Remittance Rule

TCH, the ABA, the CBA, and the BAFT (collectively, the “Associations”) submitted a comment letter in response to the Consumer Financial Protection Bureau’s Request For Information (“RFI”) regarding Potential Regulatory Changes to the Remittance Rule (“Remittance Rule”). This letter focuses on the Temporary Exception which permits banks to disclose estimated exchange rates and certain fees on remittance transfers. The exception is set to expire on July 21, 2020. The Associations do not expect a complete solution to be developed by July 2020, or in the foreseeable future, that will allow banks to provide exact disclosures for all remittance transfers. Therefore, the Associations request that the Bureau A) Recognize the distinct segment of the remittance transfer market that is served by banks; and B) Utilize its existing authority to permit banks to continue providing estimated disclosures.

Download the full comment letter here.