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Joint Comment Letter re Remittance Transfer NPRM
To Whom It May Concern:
The Clearing House Payments Company LLC (“TCH”), the American Bankers Association, the Consumer Bankers Association, and the Bankers Association for Finance and Trade (collectively, the “Associations”) respectfully submit this comment in response to the Consumer Financial Protection Bureau’s (“Bureau”) Notice of Proposed Rulemaking—Remittance Transfers under the Electronic Fund Transfer Act (Regulation E) (“Proposal” or “Remittance NPRM”).2 In the Remittance NPRM, the Bureau proposes several changes to its Remittance Transfer Rule, subpart B of Regulation E (the “Remittance Rule” or “Rule”): (1) a proposed permanent exception that, if certain conditions are met, would allow insured institutions to estimate the exchange rate for certain remittance transfers, (2) a proposed permanent exception that, if certain conditions are met, would allow insured institutions to estimate covered third-party fees for certain remittance transfers; and (3) a proposal to raise the Remittance Rule’s 100 annual remittance transfer safe harbor to 500 annual remittance transfers. This comment letter focuses on the two proposed permanent exceptions.
The Associations greatly appreciate the Bureau’s proposal to amend the Remittance Rule and find a solution to the pending expiration of the Remittance Rule’s temporary exception (§ 1005.32(b)(2)) so that consumers can continue to use bank-provided remittance transfer services. The Associations support the Proposal because, without action by the Bureau, the expiration of the Temporary Exception will have the perverse effect of reducing consumer choice, forcing bank customers to use less convenient or more expensive services, and, for some consumers, leaving them without an alternative means of sending the transfers that they send today through their banks.