CUNA Survey on CFPB Final Rule on International Remittance Transfers

Help Us Assess the Impact of the Most Recent Changes to the 2013 Final Rule



The CFPB announced April 30 that it has made a number of changes to its final rule on international remittance transfers; these are changes that CUNA advocated for on your behalf. CUNA's International Remittances Working Group has met with CFPB Director Richard Cordray and his senior staff, and CUNA senior staff have had numerous meetings and telephone conversations with CFPB officials to urge more flexibility for credit unions on remittance issues.

The changes the CFPB made include a delayed effective date of the entire rule until October 28, 2013, and additional latitude for remittance providers. The CFPB did not revisit the 100 transfers per year exemption threshold.

We want to hear from you regarding the impact of these final changes on your international remittance transfer services; we hope to share the aggregate results with the CFPB, key Members of Congress, and the National Credit Union Administration Board.

Please take a few minutes to complete the survey and provide your responses to us. Your responses will be very helpful as we continue to advocate to important policymakers in an effort to minimize the effects of the Dodd-Frank Act on international remittances. The survey begins with the rule's definition and examples regarding remittance transfers and presents questions that reflect the recent CFPB regulatory changes. For more details on the final rule changes, please access our Final Rule Analysis.

We would appreciate receiving your completed survey by June 10. If you have any questions, please contact Dennis Tsang at dtsang@cuna.coop, Jon Haller at jhaller@cuna.coop, or Connie Dey-Marcos at cdeymarcos@cuna.coop.

Thank you very much, in advance, for your assistance!


Definition of a “remittance transfer” - An electronic transfer of funds greater than $15 requested by a consumer sender (sender) to a designated recipient sent by a remittance transfer provider (provider), regardless of whether the sender holds an account with the provider or if the transaction is also an electronic fund transfer. A “remittance transfer” does not include securities or commodities transfers or any transfer that is excluded from the definition of electronic fund transfer.

The Official Commentary to the rule provides these examples of remittance transfers:


  • International consumer wire transfers;
  • International ACH transactions;
  • Transfers where the consumer sender provides cash or another method of payment to a money transmitter or financial institution and requests that funds be send to a specified location or account in a foreign country;
  • An addition of funds to a prepaid card by a participant in a prepaid card program where the prepaid card is sent or was previously sent by a participant in the prepaid card program to a person in a foreign country; or
  • Online bill payments and other electronic transfers that a sender schedules in advance, including preauthorized remittance transfers, made by the sender's financial institution at the sender's request to a designated recipient (in another country).

Remittance transfers do NOT include:

  • A consumer's provision of a debit, credit, or prepaid card, directly to a foreign merchant as payment for goods or services;
  • A consumer's deposit of funds to a checking or savings account located in the U.S., because there has not been a transfer to a designated recipient; or
  • Online bill payments and other transfers that senders can schedule in advance, made on a website of a merchant in a foreign country and via direct provision of a checking account, credit card, debit card, or prepaid card to the merchant.


Please note: When typing responses to fill-in-the-blank questions, please do not hit the [Enter] key. Doing so will submit the survey before you have finished it.


1. Based on this definition, does your credit union offer international remittance transfers to your members?



2. If you do offer these services to your members, how many transfers do you provide, on average, in a typical year?

3. This final rule provides several changes intended to facilitate compliance for remittance providers. Please indicate how helpful each of the following changes are.

Very
helpful

Somewhat
helpful

Not
helpful
Making optional the disclosure of fees imposed by a designated recipient's institution
(conditions apply; please refer to CUNA Final Rule Analysis)
Making optional the disclosure of taxes collected by a person other than the
remittance transfer provider
Eliminating a remittance provider's liability under revised error resolution provisions
that apply when a remittance transfer is not delivered to a designated recipient
because the consumer sender provided an incorrect account number or incorrect
recipient institution identifier (conditions apply; please refer to CUNA Final Rule Analysis)

4. The CFPB has extended the effective date to October 28, 2013. Will this extended effective date provide adequate time for implementation?



5. Prior to this final rule, which of the following did your credit union plan to do? (Check all that apply.)







6. In light of the delayed effective date and additional flexibility, which of the following does your credit union plan to do? (Check all that apply.)







7a. Do you currently rely on a third party (e.g., a corporate credit union or a correspondent institution) to provide international fund transfers?



7b. Will your third party facilitate or delay your readiness for the final rule?



8. What, if anything, does your credit union still need to do in order to be in compliance with the final rule?

9. Are there other aspects of the final rule for which you would like the CFPB to provide further regulatory flexibility in the future? If so, please explain.

10. What is your credit union's asset size?










11. Contact Information (Optional).


Thank you for your efforts in responding.