The Clearing House Association (TCH) submitted comments cautioning that the CFPB’s proposed rule on “Fees for Instantaneously Declined Transactions,” could encourage fintechs to take advantage of a carve out in the rule by artificially slowing some consumer payments.  The letter asserts that this would run counter to the policy objectives of both The Clearing House Payments Company and the Federal Reserve System of giving consumers increased control over their account balances through use of timing-predictable, nearly instant payments and could slow the development and delivery of faster payment innovations for consumers.  As the CFPB acknowledged, charging an NSF fees on instantaneously declined transactions is not a common in the market today.  Therefore, TCH encouraged the CFPB to withdraw the proposal at this time, collect more granular data, and continue to monitor the market for further developments.

To read the full statement click here.