On Dec. 3, 2019, the Consumer Financial Protection Bureau (CFPB) issued a proposal to amend the Remittance Rule, including addressing the expiration of the exception allowing financial institutions to estimate certain fee and exchange rate information. The 133-page proposal provides for a permanent exception to the Remittance Rule permitting insured institutions to estimate the exchange rate for a remittance transfer to a particular country if, among other things, the designated recipient will receive funds in the country’s local currency and the insured institution made 1,000 or fewer remittance transfers in the prior calendar year to that country when the designated recipients received funds in the country’s local currency. The proposal provides a permanent exception to the Remittance Rule permitting providers to use estimates for transfers to certain countries and a process for adding countries to the safe harbor countries list. The proposal would also increase the safe harbor threshold from 100 transfers to 500 transfers annually.


John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.