ARTICLE
6 December 2019

CFPB Proposes Extending Remittance Transfers Exemption

CW
Cadwalader, Wickersham & Taft LLP
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The CFPB proposed extending an exemption that allows insured institutions to disclose estimates to consumers of the exchange rate and covered third-party
United States Consumer Protection
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The CFPB proposed extending an exemption that allows insured institutions to disclose estimates to consumers of the exchange rate and covered third-party fees instead of exact amounts when sending international money transfers, or remittance transfers. The exemption is currently set to expire on July 21, 2020.

According to the CFPB, the proposal to amend Regulation E ("Electronic Fund Transfers") would allow consumers to continue to send remittances from their bank accounts to various destinations while also lessening the burden of compliance for banks and credit unions. The CFPB stated that the estimates disclosed to consumers would be allowed when it is economically infeasible to provide exact figures.

The CFPB stated that the proposal would also increase a safe harbor threshold when remittance transfers are made under "the normal course" of business, ultimately reducing the compliance cost for entities making 500 or fewer remittance transfers annually (up from 100).

Comments on the proposal must be submitted within 45 days after publication in the Federal Register.

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ARTICLE
6 December 2019

CFPB Proposes Extending Remittance Transfers Exemption

United States Consumer Protection
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
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