John Zasada, Compliance Consulting Director, Financial
Institutions Group

On May 11, 2020, the Consumer Financial Protection Bureau (CFPB) issued a 153-page final rule increasing the threshold for determining institutions subject to the remittance rule to 500. The remittance rule implements provisions in Regulation E related to disclosures of specific exchange rates and third-party fees for remittance transfers. The remittance rule permits financial institutions to provide estimates of the exchange rate and fees in certain circumstances.

One of the circumstances allowing financial institutions to provide estimates was if an institution provided 100 or less remittance transfers annually. The final rule increases the threshold for allowing estimates to 500 or less. This will permit over 400 banks and almost 250 credit unions to provide estimates of exchange rates and third-party fees. The final rule takes effect July 21, 2020.

If you have questions about your remittance transfer operations, contact Doeren Mayhew’s regulatory compliance specialists.