The CFPB’s Remittance Transfers rule has been in effect since October 2013 as subpart B of Regulation E. There was a September 2014 amendment that clarified the status of U.S. military installations overseas and certain other issues, and in June 2020 we got another set of amendments that increased the “safe harbor” exemption threshold from the rule to 500 remittance transfers.
Yet the regulation remains complex. There are provisions for delivering disclosures electronically, but they are limited. Some disclosures can be made orally, but only in specific situations. With the increased safe harbor amendments, insured banks and credit unions received broader exemptions from certain disclosure accuracy requirements, but with those exemptions came more complex recordkeeping to justify those exemptions.
The basics of the rule are unchanged. There are pre-purchase disclosures and receipt disclosures. Certain accuracy requirements are mandated (with some exceptions). A consumer has rights to cancel a transfer and, when things don’t go exactly as planned, to make claims of errors or non-delivery of funds.
In this two-hour presentation, BOL Guru John Burnett will explain –
- Who is protected by the rule
- Which transfers are covered
- Transfers to U.S. territories and military installations overseas
- The safe harbor limit on exemptions
- Pre-purchase disclosures
- When oral and electronically delivered disclosures are permitted (and when they are not)
- Receipt disclosures and combined disclosures
- Disclosure timing rules
- The provision allowing estimates of exchange rates for certain countries
- The provision for estimating covered third-party fees for certain transfers
- The ins and outs of error resolution